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SB 505 - PID or Inspect Every 5 years

avrojockey

Well Known Member
Patron
So...I recently took the LSRM class by Rainbow Aviation (great BTW) and used my aircraft records in class for AD/SB research. Here's a little hidden nugget I found when I continued the search at home...

  1. AD98-02-08 / SB505 was never done...records show not applicable
  2. AD98-02-08 isn't applicable because I have -E2D converted to 160hp which makes it experimental (no STC paperwork or "C" stamp on data plate)

I rolled the dice and completed SB 505 just for peace of mind, and fortunately there was a .100 layer of lead(?) sludge protecting the ID of the crank...no corrosion or pitting :D.

Here's my question...should I do SB 530B and PID with Urethabond 104 or just reinspect every 5 years IAW SB 505. I fly every week and aircraft is hangared in WI so there's seemingly nil corrosion risk, so I'm leaning towards just inspection every 5 years. I can buy a lot of crank plugs for the cost of Urethabond 104.
 
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Are you thinking about applying the coating so you can stamp PID and don?t have to reinspect? Is the engine apart or is this something that you are flying? Step 1 says in order to apply the coating, remove crank. I wouldn?t remove the crank just to do the coating, just reinspect and clean the gunk..my opinion..
 
So...I recently took the LSRM class by Rainbow Aviation (great BTW) and used my aircraft records in class for AD/SB research. Here's a little hidden nugget I found...

  1. AD98-02-08 / SB505 was never done...records show not applicable
  2. AD98-02-08 isn't applicable because I have -E2D converted to 160hp which makes it experimental (no STC paperwork or "C" stamp on data plate)

I rolled the dice and completed SB 505 just for peace of mind, and fortunately there was a .100 layer of lead(?) sludge protecting the ID of the crank...no corrosion or pitting :D.

Here's my question...should I do SB 530B and PID with Urethabond 104 or just reinspect every 5 years IAW SB 505. I fly every week and aircraft is hangared in WI so there's seemingly nil corrosion risk, so I'm leaning towards just inspection every 5 years. I can buy a lot of crank plugs for the cost of Urethabond 104.

first, i agree that i would not tear it down just to do the coating, do it at the next overhaul.
as to it not applying because it is experimental, the FAA does not agree. the AD says "but not limited to...." the FAA takes the stand that it left the factory as a a lycoming, so it is still a lycoming, experimental or not. because it has been upgraded to 160HP the AD applies. a lot of people do not agree, but the FAA say its that way. fight them if you wish.

bob burns
RV-4 N82RB
 
That layer of sludge is what causes the pitting and isn't protecting anything! The coating that the ad calls out to eliminate the inspections is protecting the ID surface from the sludge!
Good Luck,
Mahlon
 
Corrosion

Mahlon is right, the sludge holds corrosive byproducts of the combustion process. I?ve found rust pitting under the sludge several times. Don?t know if being hangared makes any difference in this case or not. Not common, but I?ve also seen the PID coating have missing spots. The constant speed cranks have less issues because oil flows thru this area. My planes and the ones under my care get looked at every 3-5 years (and a new Alt belt) or sooner if it?s convenient. If the prop is off you almost there.

Don Broussard
RV9 Rebuild in Progress
57 Pacer
 
as to it not applying because it is experimental, the FAA does not agree. the AD says "but not limited to...." the FAA takes the stand that it left the factory as a a lycoming, so it is still a lycoming, experimental or not. because it has been upgraded to 160HP the AD applies. a lot of people do not agree, but the FAA say its that way. fight them if you wish.

bob burns
RV-4 N82RB

Firstly, I hope that you would know my motivations with regards to safety given I performed the SB regardless my assumption that the AD doesn't apply. Please frame these questions in this context.

I agree that "but not limited to" could effect the applicability of AD in the form of any aircraft type certification...this is clearly stated in AC 39-7D. However, if one modifies an engine and it no longer conforms to the TCDS, I would assume Lycoming, from a legal standpoint, would agree that it's no longer a Lycoming. My engine (E2D) has been modified in a way that it no longer conforms to TCDS E-274...I have electronic ignition and 8.5:1 pistons. So playing devils advocate...

1. What is my engine legally? Is it a Lycoming if it doesn't conform to TCDS?
3. If so, what level of modification makes it other than a Lycoming? Can I modify every part of the engine but the data plate and still call it a Lycoming O-320-E2D?
2. AD98-02-08 clearly states Lycoming O-320 series limited to 160 HP. With all the non-STC'd modifications, what is the rated HP of my engine?
4. If I have a O-320-Dxx and modified it to 7.0:1 pistons to burn mogas is it subject to the AD?
5. Could I take my "O-320-E2D" in it's current state and install on the C-172 from which it came?

I hope these question are not found in ill regard. When talking about the law of AD applicability it's important to ensure legal definitions. I would like to know if there's any interpretation from FAA legal in this regard, rather than to simply opine.
 
Mahlon is right, the sludge holds corrosive byproducts of the combustion process. I’ve found rust pitting under the sludge several times. Don’t know if being hangared makes any difference in this case or not. Not common, but I’ve also seen the PID coating have missing spots. The constant speed cranks have less issues because oil flows thru this area. My planes and the ones under my care get looked at every 3-5 years (and a new Alt belt) or sooner if it’s convenient. If the prop is off you almost there.

Don Broussard
RV9 Rebuild in Progress
57 Pacer

Great advice on belt before my prop is back on!

Regarding sludge...I clean it out to about 4.5" but didn't go all the way back for fear of disturbing things I couldn't easily see as I was cleaning, and contaminating oil. Would you recommend cleaning out fully? If so, could I wait until next 505 since I already installed the crank plug?

Edit: I just reread SB505 and it explicitly says to clean 3.5"...I'll venture to say do more could induce risk.
 
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Firstly, I hope that you would know my motivations with regards to safety given I performed the SB regardless my assumption that the AD doesn't apply. Please frame these questions in this context.

I agree that "but not limited to" could effect the applicability of AD in the form of any aircraft type certification...this is clearly stated in AC 39-7D. However, if one modifies an engine and it no longer conforms to the TCDS, I would assume Lycoming, from a legal standpoint, would agree that it's no longer a Lycoming. My engine (E2D) has been modified in a way that it no longer conforms to TCDS E-274...I have electronic ignition and 8.5:1 pistons. So playing devils advocate...

1. What is my engine legally? Is it a Lycoming if it doesn't conform to TCDS?
3. If so, what level of modification makes it other than a Lycoming? Can I modify every part of the engine but the data plate and still call it a Lycoming O-320-E2D?
2. AD98-02-08 clearly states Lycoming O-320 series limited to 160 HP. With all the non-STC'd modifications, what is the rated HP of my engine?
4. If I have a O-320-Dxx and modified it to 7.0:1 pistons to burn mogas is it subject to the AD?
5. Could I take my "O-320-E2D" in it's current state and install on the C-172 from which it came?

I hope these question are not found in ill regard. When talking about the law of AD applicability it's important to ensure legal definitions. I would like to know if there's any interpretation from FAA legal in this regard, rather than to simply opine.

I wasn't going to derail your thread by going off topic but since you are asking specific questions on the subject, here is a couple snips from a presentation I have given called A&P's and non-type certificated aircraft . The entire presentation is in the downloads section of the Van's website.

Do FAA issued AD’s (by regulation) apply to Experimental Aircraft?
• Technically, no.
• FAA has authority to issue an AD against any aircraft operating in U.S. airspace except under
Part 129. FAA’s ability to issue AD’s is limited by practical considerations. The FAR do not
support AD’s for non-TC’ed aircraft. If FAA issues an AD against a non-TC'ed’ aircraft, it could
be challenged strongly in court for violating its own rules. AGC (FAA Legal Council) is adamant in
this. FAA refrains from AD's’ for experimental amateur-builts and foreign manufactured nonTC'ed’ aircraft.
(From an Aircraft Certification Management Team Report published in 1998)


So, the FAA legal department has gone on record saying AD's don't apply to experimentals.

But, in the next page of the presentation I say this.....

Should FAA issued AD’s be applied to
Experimental category aircraft?

• Yes

Remember that the certification statement for the completion of a condition inspection is “I certify
that………. and was found to be in a condition for safe operation

The potential issues being addressed by the issuance of an AD are (usually) going to be as relevant
on an experimental as they are on a Type Certificated aircraft. Because there is some latitude
from a regulatory standpoint, a mechanic can use their own judgement if they choose to.


So in a legal context they are not binding, but if an incident or accident ever occurred that appeared to be at all related to to something addressed with an AD, the person that signed off the last condition inspection as being in a condition for safe operation could be asked to explain why they did so when there was the potential for the existence of an unsafe condition.
 
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I wasn't going to derail your thread by going off topic but since you are asking specific questions on the subject, here is a couple snips from a presentation I have given called A&P's and non-type certificated aircraft . The entire presentation is in the downloads section of the Van's website.

Do FAA issued AD?s (by regulation) apply to Experimental Aircraft?
? Technically, no.
? FAA has authority to issue an AD against any aircraft operating in U.S. airspace except under
Part 129. FAA?s ability to issue AD?s is limited by practical considerations. The FAR do not
support AD?s for non-TC?ed aircraft. If FAA issues an AD against a non-TC'ed? aircraft, it could
be challenged strongly in court for violating its own rules. AGC (FAA Legal Council) is adamant in
this. FAA refrains from AD's? for experimental amateur-builts and foreign manufactured nonTC'ed? aircraft.
(From an Aircraft Certification Management Team Report published in 1998)


So, the FAA legal department has gone on record saying AD's don't apply to experimentals.

But, in the next page of the presentation I say this.....

Should FAA issued AD?s be applied to
Experimental category aircraft?

? Yes

Remember that the certification statement for the completion of a condition inspection is ?I certify
that???. and was found to be in a condition for safe operation?

The potential issues being addressed by the issuance of an AD are (usually) going to be as relevant
on an experimental as they are on a Type Certificated aircraft. Because there is some latitude
from a regulatory standpoint, a mechanic can use their own judgement if they choose to.


So in a legal context they are not binding, but if an incident or accident ever occurred that appeared to be at all related to to something addressed with an AD, the person that signed off the last condition inspection as being in a condition for safe operation could be asked to explain why they did so when there was the potential for the existence of an unsafe condition.

Thanks Scott! This certainly falls in line with my actions. I certainly want operate the aircraft legally and safely, and want to present a safe aircraft to the A&P that completes my condition inspection. I would expect nothing less.
 
One of the mechanics at the FBO where I rented back in 1998 forgot the last sentence in this snippet from SB 505B when he did it:

"To ensure that contaminants from the cleaning process and the FPI do not enter the engine oil supply, block off the area of the crankshaft bore that is aft of the area being inspected by using a clean, dry, lint-free cloth. When the FPI is completed remove the lint-free cloth from the crankshaft bore before installing the front crankshaft plug."


Here is the story (with pics) of my subsequent off-airport landing because of that slip up:


Also goes to show that the first flight after any maintenance should be a test flight.

Wow! Fantastic airmanship. Glad it was your story to tell and not others!
 
I wasn't going to derail your thread by going off topic but since you are asking specific questions on the subject, here is a couple snips from a presentation I have given called A&P's and non-type certificated aircraft . The entire presentation is in the downloads section of the Van's website.

Do FAA issued AD?s (by regulation) apply to Experimental Aircraft?
? Technically, no.
? FAA has authority to issue an AD against any aircraft operating in U.S. airspace except under
Part 129. FAA?s ability to issue AD?s is limited by practical considerations. The FAR do not
support AD?s for non-TC?ed aircraft. If FAA issues an AD against a non-TC'ed? aircraft, it could
be challenged strongly in court for violating its own rules. AGC (FAA Legal Council) is adamant in
this. FAA refrains from AD's? for experimental amateur-builts and foreign manufactured nonTC'ed? aircraft.
(From an Aircraft Certification Management Team Report published in 1998)


So, the FAA legal department has gone on record saying AD's don't apply to experimentals.

But, in the next page of the presentation I say this.....

Should FAA issued AD?s be applied to
Experimental category aircraft?

? Yes

Remember that the certification statement for the completion of a condition inspection is ?I certify
that???. and was found to be in a condition for safe operation?

The potential issues being addressed by the issuance of an AD are (usually) going to be as relevant
on an experimental as they are on a Type Certificated aircraft. Because there is some latitude
from a regulatory standpoint, a mechanic can use their own judgement if they choose to.


So in a legal context they are not binding, but if an incident or accident ever occurred that appeared to be at all related to to something addressed with an AD, the person that signed off the last condition inspection as being in a condition for safe operation could be asked to explain why they did so when there was the potential for the existence of an unsafe condition.

i totally agree with you on ADs and experimental aircraft. the question however, is what about a engine,prop, or accessory that was produced under a TCDS and is now on a experimental aircraft. The FAA is, as alwas all over the chart on it.

Yes, I know AC's are not regulatory. but the FAA will sure throw them at you in an investigation. AC 39-7d says:


b.Non-TC?d Aircraft and Products Installed Thereon. Non-TC?d aircraft (e.g., amateur-built aircraft, experimental exhibition) are aircraft for which the FAA has not issued a TC under part 21. The AD applicability statement will identify if the AD applies to non-TC?d aircraft or engines, propellers, and appliances installed thereon. The following are examples of applicability statements for ADs related to non-TC?d aircraft: (1)?This AD applies to Honeywell International Inc. Auxiliary Power Unit (APU) models GTCP36-150(R) and GTCP36-150(RR). These APUs are installed on, but not limited to, Fokker Services B.V. Model F.28 Mark 0100 and F.28 Mark 0070 airplanes, and Mustang Aeronautics, Inc. Model Mustang II experimental airplanes. This AD applies to any aircraft with the listed APU models installed.? This statement makes the AD applicable to the listed auxiliary power unit (APU) models installed on TC?d aircraft, as well as non-TC?d aircraft. (2)?This AD applies to Lycoming Engines Models AEIO-360-A1A and IO-360-A1A. This AD applies to any aircraft with the listed engine models installed.? This statement makes the AD applicable to the listed engine models installed on TC?d and non-TC?d aircraft.

so I would argue that the final legal ruling may be that no it doesn't apply, since the lawyer department say that,but since a different part of the FAA says 'yes it does" i don't want to be the checkbook that has to pay to find out what a judge says it really means.

bob burns
RV-4 N82RB
 
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