Introduction
The following article is
based on an investigation and analysis of an aircraft accident of one
Hughes 369D helicopter (Hughes 500D) equipped with one Rolls-Royce
250-C20B gas turbine engine. I was retained by the defense council as
an Expert Witness in this case which resulted in a fatality.
Information that was used to support these conclusions are listed at
the end of this article. A physical and lab examination was performed
on the accident engine components at a metallurgy forensic lab. Note that names, dates, document numbers, etc. have been changed and/or X'ed out to protect the privacy of the involved parties.
Engine Failure
The helicopter experienced a
sudden and total engine failure while stationary in an
out-of-ground-effect hover at approximately 120 feet above the
ground. The pilot was performing an inspection of power lines and
their support towers at the time of the engine failure. This sudden
failure occurred without any warning and resulted in a total loss of
power. A post-accident engine investigation performed by Rolls-Royce
(RR), and overseen by the FAA, concluded that the cause of the
failure was due to blade separation of the 2nd stage gas
producer turbine wheel. It was determined that the blade separation
was caused by high cycle fatigue (HCF) and over-temperature thermal
stress. The HCF is attributed to a localized over-temperature
condition (hot spot) that was evident by an area of complete
burn-through to a section of the 1st stage turbine nozzle
assembly around the 11 o'clock position. There was also evidence of
an uneven flame pattern indicated by non-uniform discoloration of the
combustion liner. This uneven flame distribution, which caused the
thermal damage, was the direct result of a streaking fuel nozzle.
These conclusions of the turbine failure were corroborated by a very
highly regarded independent Expert specializing in engine metallurgy
failure analysis.
Fuel Nozzle Discussion
The fuel nozzle streaking was caused by
carbon build-up near the nozzle tip which disrupted the atomized
spray pattern cone. This disruption caused a stream of non-atomized
raw liquid fuel to enter the combustor. This concentration of raw
fuel burned in a localized area near the 11 o'clock position of the
1st stage nozzle at temperatures in excess of the safe
operating limits of the combustion section (hot section). This
localized over-temperature condition was undetected and was allowed
to continue to the point that the internal components of the engine
hot section were permanently damaged resulting in failure.
The fuel nozzle streaking had developed
sometime within the last 235 flight hours and had continued to streak
without detection. This condition went undetected due to the fact
that the only reliable method to determine that a fuel nozzle is
functioning properly is to perform the fuel nozzle maintenance per
the RR maintenance manual, which had not been accomplished.
Maintenance Requirements
The engine manufacturer (RR) has
developed and refined a maintenance program based on the production
of over 30,000 RR 250 series engines with a production run spanning
50 years. The 250 series engine has accumulated an operating history
of over 200 million fleet flight hours to date. This maintenance
program contains a detailed checklist in the RR 250-C20 Series
Operation and Maintenance Manual (OMM), chapter 72-00-00, Table 602
titled, “Scheduled Inspections.” The RR 250-C20 Series OMM
states, “Scheduled inspections are made at periodic intervals in an
effort to prevent engine malfunction and serve in the role of
preventative maintenance for the engine.” This inspection checklist
details the actions required to be performed during each inspection
interval. One of the items contained within the “100 Hour
Inspection” section is 21.A and states, “Remove, inspect and
clean the fuel nozzle,” and, “NOTE: Operators may find it
necessary to inspect and clean the fuel nozzle more often depending
on past experience or operating conditions.”
This engine utilizes only one fuel
nozzle and therefore it is an extremely critical component. The 100
hour inspection requirement of the fuel nozzle has developed over the
years through field experience and is considered the absolute maximum
number of flight hours allowable between inspections. The OMM chapter
73-10-03 states “NOTE: Due to variation in fuels and operating
conditions, fuel nozzle cleaning may be necessary at more frequent
intervals then stated in Table 602, 72-00-00, Engine –
Inspection/Check, to maintain proper combustion flame pattern.” The
critically important nature of this fuel nozzle maintenance cannot be
overstated.
Maintenance Records
Investigation
The accident helicopter was operated
and maintained by (name withheld, hereafter referred to as the
Company). A thorough investigation of the helicopter's maintenance
records revealed that the 100 hour fuel nozzle maintenance was not
being performed as required by the engine manufacturer. The records
indicate that the last documented fuel nozzle maintenance was
performed 234.9 flight hours prior to the accident. The records also
indicate that over the last 1097 flight hours, the fuel nozzle
maintenance had only been performed two times (ref. Figure 1). RR
requires that the fuel nozzle be removed, inspected and cleaned at
intervals not to exceed 100 hours and that the operator should
consider even shorter time intervals depending on their past
experience or operating conditions.
There is considerable evidence
contained in the Company maintenance records, wherein the information
contained in one record conflicts with another record of the same
inspection and date. Also, the checklists that were used to perform
maintenance were inconsistent. After examining the records of 11 of
the last 100 hour inspections, dating over a one year period, it was
apparent that the maintenance personnel had been using
incorrect/outdated checklists during most of those inspections (ref.
Figure 1). Only on two occasions had the correct checklists been
used. The correct checklist that should have been used is contained
in the OMM chapter 72-00-00 Table 602 with a revision date of June 1,
2004 and required that the fuel nozzle be maintained each 100 hours.
The use of any other prior dated checklist after the effective date
of the June 1, 2004 checklist revision, would not be approved or
acceptable.
Multiple maintenance records contained
conflicting information. For example, on some of the Company forms
titled “Approval for the Return
to Service,” the maintenance personnel signed off that a specific
inspection was complied with. However, on the checklist used to
perform that maintenance, that specific inspection item is not shown
to have been complied with. Therefore these two records are in
conflict with one another.
Another issue is
that it is unclear as to what type of maintenance inspection program
the Company was actually using to comply with the airworthiness
requirement set forth by the FARs. The records reviewed indicated
that they were using the Manufacturer's Inspection Program including
the checklists contained within those programs. The Company's
“Approval for Return to Service” form contains a printed
statement as follows, “This aircraft is in a 100 Hour / Annual /
Manufacturer's Inspection Program CFR 43.15 (b), (c)(1)(3).”
However, a letter addressed to the NTSB from a Company representative
states, “the Company, at that time, was not performing its
maintenance under that program, nor was it required to.” This was
in reference to the manufacturer's program. He signed with the title,
Director of Safety/Regulatory Compliance. His statement is in direct
conflict with the Company's maintenance records.
The fact that the
Company did not adhere to the RR maintenance program, used outdated
documentation to perform maintenance, and that their own maintenance
records are in conflict with each other, are all indicators that the
Company's maintenance was substandard, negligent, inconsistent with
industry standards, and compromised the safety of flight and rendered
it unreasonably dangerous. The Company's maintenance records reflect
a standard of care that breached the aviation industry's level of
acceptance, manufacturer's specifications and violated applicable
FARs.
100
Hour Inspection Maintenance Records
Figure
1
A
|
B
|
C
|
D
|
E
|
AFTT
|
Date
|
Fuel Nozzle Maint. per Checklist
|
Fuel Nozzle Maint. per RTS Form
|
Checklist Used
|
10816.3
|
05/28/07
|
Accident
|
10773.6
|
05/13/07
|
No
|
No
|
Old
|
10670.9
|
04/12/07
|
No
|
No
|
Old
|
10581.4
|
02/25/07
|
Yes
|
Yes
|
New
|
10478.3
|
01/11/07
|
No Record
|
Yes
|
No Record
|
10381.1
|
12/12/06
|
No
|
Yes
|
Old
|
10283.2
|
11/11/06
|
No Record
|
Yes
|
No Record
|
10200.0
|
10/13/06
|
No
|
Yes
|
Old
|
10103.4
|
09/17/06
|
No
|
Yes
|
Old
|
10005.9
|
08/22/06
|
Yes
|
Yes
|
New
|
9905.8
|
08/03/06
|
No
|
Yes
|
Old
|
9809.1
|
07/17/06
|
No
|
Yes
|
Old
|
9719.7
|
06/21/06
|
Overhauled Fuel Nozzle Installed by
the Company
|
NOTES:
A.
Total flight hours at time of inspection.
C.
Documented fuel nozzle maintenance recorded on the RR checklist.
D.
Documented fuel nozzle maintenance recorded on the Company's return
to service form.
E.
Checklist used to perform the inspection. This is contained in the RR
OMM Table 602. The new Table 602 has a revision date of June 1, 2004.
Columns
C & D show conflicting information.
Column E shows outdated checklist being used.
Maintenance
Considerations
Fuel nozzle
removal, inspection and cleaning is the only way to detect a
condition that could lead to or cause fuel streaking and it is
critical since there is no other way to determine a localized
over-temperature condition. An early detection of a streaking fuel
nozzle can preclude irreversible internal engine component damage.
Had the fuel nozzle maintenance been performed in accordance with RR
procedures, the malfunctioning fuel nozzle would have been discovered
and the problem corrected. It is highly likely that an early
discovery of such a condition would have prevented hot section damage
and turbine failure. This discovery could have alerted the operator
that it would be prudent to perform a simple borescope inspection of
the hot section to determine if any signs of thermal stress/damage
had occurred due to the streaking fuel nozzle. If any signs of
thermal damage were discovered at this early stage, the procedure
would be to perform a hot section inspection in accordance with RR
instructions to determine the extent of the damage prior to further
flight. This procedure would prevent an in-flight engine failure due
to thermal damage.
The
Company's Operations and Risk Assessment
The
Company performs aerial power
line inspection, maintenance and construction for the electrical
utility industry utilizing helicopters. Typical day-to-day operations
performed by the Company
require
that the helicopter and its occupants be exposed to extreme risk for
a majority of the flight profile. The helicopter spends most of its
flight time operating outside of the established safe autorotation
envelope contained in the helicopter's height/velocity
(H/V) curve. An autorotation is a descending maneuver, or power-off
glide, which allows the helicopter to safely land in the event of a
loss of power. The H/V curve is established by the helicopter
manufacturer and is depicted by a graphical chart which illustrates
which combinations of altitude and airspeed allow a safe
autorotational landing in the event of engine failure. Operations
outside the safe area of the chart expose the helicopter's occupants
to extreme risk in the event of an engine failure. This is due to the
fact that it is unlikely that the pilot will be able to accomplish a
safe autorotation under this set of conditions following an engine
failure, as demonstrated in this fatal accident. This area is
commonly referred to as the “dead mans curve.” At the time of the
engine failure, the helicopter was in a stationary hover
out-of-ground-effect at 120 feet above the ground. This flight
profile put the helicopter in the “dead man's curve.”
In light of this
fact, an operator should understand these risks and elect to perform
it's maintenance above and beyond the minimum recommended standards.
The Company was very aware of these risks, yet they have demonstrated
that the standard of care they used regarding their maintenance is
well below that of the industry's acceptable standard of safety.
The
Company had posted a video
titled “Company is
Seeking Pilots and Aerial Linemen.” In this video the President,
states “You're taking two very dangerous things, electricity and
hovering in the height velocity curve, dead mans curve, most of your
career,” and, “Ninety percent of his (pilot) time is sitting in
one spot (hovering).”
Federal
Aviation Regulations (FAR) Compliance Requirements
An investigation of
the helicopter maintenance records shows that the Company was using
the airframe and engine manufacturer's maintenance programs. These
maintenance programs allow the helicopter operator to maintain the
airworthiness status of the helicopter on a continuing basis,
provided the programs are strictly adhered to. The RR engine
maintenance program was used to maintain the engine, however, the
scope and detail contained in the scheduled inspections in the OMM
chapter 72-00-00 Table 602 of that program was not strictly adhered
to. This table contains the Inspection Checklist for each type of
inspection, IE, 100 Hour Inspection, 200 Hour Inspection, etc.
As shown in Figure
1 above, the Company was either using an incorrect engine checklist
or none at all for a majority of the 100 hour inspections. On only
two inspections were the correct checklists used. The correct
checklist required the fuel nozzle to be inspected each 100 hours
whereas the incorrect and outdated checklist did not have this
requirement. It was the use of this incorrect checklist that caused
the maintenance personnel to overlook this critically important
inspection item. The correct 100 hour checklist contained this fuel
nozzle inspection, therefore, if the Company had been using the
correct checklist, maintenance personnel would have realized that the
fuel nozzle inspection was a part of the required inspection items.
According to the
Federal Aviation Administration (FAA) such an oversight would be
considered an issue of non-compliance with the manufacturer's
maintenance program, and as such would constitute a violation of the
FARs and breach the aviation industry's level of acceptance. This
state of non-compliance would render the helicopter unairworthy due
to the fact that the maintenance program was not being adhered to as
specified by the scope and detail contained within that program.
The FAA has
established the FARs to
regulate and guide the operator to promote flight safety. Therefore,
the FARs are material to flight safety. Non-compliance with the FARs
materially affects the safety of flight since such a violation would
have a negative impact on that which is relevant and significant to
flight safety. Compliance with the FARs is the absolute minimum
standard of care that an operator must abide by.
It
is not clear at this time whether the Company was required to
maintain the helicopter under FAR Part 91 or Part 135. This is due to
the fact that this information has been requested but has not yet
been produced. If the helicopter had been maintained under Part 91,
the Company was in violation of Part 91 Subpart E, 91.409 (e). If the
helicopter had been maintained under Part 135, the company was in
violation of Part 91 Subpart E, 91.409 (c) (2) and Part 135 Subpart
J, 135.421 (a) & (b).
Engine Overhauler (name
withheld) Work Performed
Research of the engine maintenance
records shows that the Engine Overhauler had performed an overhaul of
the fuel nozzle, part number 23077068, and that the Company installed
this fuel nozzle on the helicopter after the overhaul. Research of
the Engine Overhauler's records of work performed on this fuel nozzle
indicate that they did a functional test as received. The test
indicated that voids and streaks were noted at all PSIs prior to any
work being performed. They completed the overhaul per the Rolls-Royce
Overhaul Manual 10W3, Edition 4 Revision 1, dated August 15, 2004,
and complied with AD 2004-24-09, CEB A-1394 R1, incorporated MOD PMI
G0005 and installed a new filter assembly, part number 139968, per
Service Bulletin 1394. After completion of the overhaul, the fuel
nozzle was tested in accordance with the Overhaul Manual to overhaul
limits and the results were documented on the “Fuel Nozzle
Calibration Record” form. This record indicates that the fuel
nozzle had a final functional test performed after the overhaul to
verify that it met all the overhaul limits as specified in the
Overhaul Manual. The records show that the fuel nozzle met all the
required parameters and did not exhibit any hysteresis or spray
pattern anomalies.
The Engine
Overhauler's procedures and records regarding the fuel nozzle
overhaul are well documented, consistent with the regulations, and
the standard of care exceeded the industry norm. There were no
discrepancies, conflicts, irregularities or errors contained in those
documents. Based on these observations, the Engine Overhauler
performed the overhaul in compliance with both the FARs and the
manufacturer's mandatory overhaul procedures and standards, and
without any wrongdoing.
Conclusions
I have performed a thorough
investigation and review of the documentation, and inspection of the
accident helicopter engine components. As an expert in aircraft
maintenance and operations, within a reasonable degree of certainty,
my professional opinions are:
The overhaul of the
fuel nozzle was performed in accordance with industry standards and
was without negligence or wrong doing,
The fuel nozzle was functioning
normally and and met all required specifications at the time of its
release by the Engine Overhauler,
The fuel nozzle continued to
function normally for hundreds of flight hours and months of
operations after its release by the Engine Overhauler,
The work performed by the Engine
Overhauler was in no way related to the malfunction of the fuel
nozzle or to the failure of the engine, which occurred approximately
1097 hours after the performance of their work,
The Engine Overhauler did not
breach any applicable standards, codes or regulations of any kind
regarding its work performed on the helicopter's engine and
components,
The Engine Overhauler's work
performed on the helicopter's engine and components was not causal
to the helicopter's engine failure,
The Company, as operator of the
helicopter, had the duty to maintain that helicopter in accordance
with the FARs and industry standards, but did not do so, failing to
fulfill their duty as an operator and breaching an acceptable
standard of care,
The Company did not maintain the
helicopter's maintenance records in accordance with the FARs and
industry standards,
The Company's substandard
maintenance and record keeping, along with a disregard to follow the
manufacturer's maintenance program, demonstrated a lack of standard
of care and is inconsistent with aviation industry standards,
The Company substandard approach
to maintenance led to the use of incorrect inspection checklists,
which in turn led to the critical inspection of the fuel nozzle
being overlooked,
The lack of proper fuel nozzle
maintenance by The Company led to fuel nozzle streaking,
This streaking was allowed to go
undetected due to the fact that the fuel nozzle was not being
removed and inspected at each mandated 100 hour interval, thereby
causing an over-temperature condition within the hot section. The
over-temperature condition caused thermal stress and high cycle
fatigue (HCF) of the 2nd stage turbine wheel blade which
led to the sudden engine stoppage. This inspection was critical
since there is no other way to determine a localized
over-temperature condition,
Items 7 through 12 above caused
the engine failure which led to the fatal accident.
Lessons Learned
It is always a sad
day when we have to look at a fatal aircraft accident to again be
reminded of the obvious: Preventative maintenance is a very
valuable tool and one that should be taken seriously. This
accident should have never happened. It is my opinion that had the
manufacturer's maintenance instructions been carried out, to the
letter, this engine failure would never had happen.
Qualifications
I am qualified to review,
analyze and offer my expert opinion regarding this accident based on
the following experience:
I have 37 years of
professional experience working in the aviation industry as both a
pilot and as a mechanic. I have hands-on experience with the
Rolls-Royce 250 series gas turbine engine, both from the operations
side as a commercial helicopter pilot and from the maintenance side
as a mechanic and Chief Inspector. These operations were conducted
under FAR part 91, 133, 135, and 145 Repair Station. I hold an
Airline Transport Pilot (ATP) pilot certificate, Airframe and
Powerplant (A&P) and Inspection Authorization (IA) Mechanics
certificates. This combined experience qualifies me to render expert
opinion in this case.
Reference Documents and
Data Reviewed
Rolls-Royce
Engine Investigation Report, dated XX/XX/XXXX, including appendices
A - J
NTSB Factual
Report ID: XXXXXX
NTSB Probable
Cause
NXXXX
maintenance records including airframe and engine
Rolls-Royce
250-C20 Series Operation and Maintenance Manual (OMM)
Rolls-Royce
250-C20 Series Illustrated Parts Catalog (IPC)
The
Engine Overhauler's records pertaining to work performed on engine
CAE XXXXXX and components
Emails
between Rolls Royce representatives
FAA
issued ADs and RR issued CEBs applicable to this engine
Code
of Federal regulations (CFR) Title 14
Photographs
taken at the lab inspection
Photographs
taken by Rolls-Royce expert
Letter
dated XX/XX/XXXX from the Company to the NTSB
-
-
Complaint
and Demand for Jury Trial, XXXX vs. XXXX, Cause No. CV XX-XX RFC