Narrative:

A local flight school sent me a fuel tank off of a piper warrior which was leaking. The leak was caused when a mechanic at their facility punctured the side of the tank with a screwdriver. I was asked to repair the tank and return it to them and they would take care of the paperwork at their facility in conjunction with other work in progress on the aircraft in question. The tank is all aluminum construction. The repair involved disassembly of the tank by removing the rivets around the outside edges which then was separated into the two major components of the tank. The punctures were then resealed and the tank reassembled using tank sealant and new rivets. This repair was very straight forward and I am fully capable of making it. It is similar in process to other aircraft. The repair was a total success and was reinstalled on the aircraft by them. It was then decided by the local flight school that they wanted a form 337 filed since this constitutes a major repair. I asked them to bring me the aircraft maintenance manual so I could quote the necessary references and make the necessary paperwork. The maintenance manual makes no provision for this type of repair. Obviously I did not consult the manual prior to making the repair. It states that a tank should be sent to a 145 repair station authority/authorized to repair this type of tank. I did not see anything special about the process of repairing this tank when I received it. All of the procedures are clearly outlined in AC43.13-1A to make similar types of repairs, I therefore simply did the repair assuming that it was common and would surely be outlined in the maintenance manual. Callback conversation with reporter revealed the following information: the reporter stated the repair was removing the rivets and resealing the tank and only after the repair was completed did the question come up about the repair manual reference to tank repair. The reporter said it was considered a major repair to be accomplished at a certified repair station only. The reporter stated the regulations are really not clear on what is and is not a major repair. The reporter said no contact has been made by the FAA.

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Original NASA ASRS Text

Title: A PA28 WARRIOR FUEL TANK WAS REPAIRED BY A LICENSED MECH BUT NOT REPAIRED AT A CERTIFIED REPAIR STATION.

Narrative: A LCL FLT SCHOOL SENT ME A FUEL TANK OFF OF A PIPER WARRIOR WHICH WAS LEAKING. THE LEAK WAS CAUSED WHEN A MECH AT THEIR FACILITY PUNCTURED THE SIDE OF THE TANK WITH A SCREWDRIVER. I WAS ASKED TO REPAIR THE TANK AND RETURN IT TO THEM AND THEY WOULD TAKE CARE OF THE PAPERWORK AT THEIR FACILITY IN CONJUNCTION WITH OTHER WORK IN PROGRESS ON THE ACFT IN QUESTION. THE TANK IS ALL ALUMINUM CONSTRUCTION. THE REPAIR INVOLVED DISASSEMBLY OF THE TANK BY REMOVING THE RIVETS AROUND THE OUTSIDE EDGES WHICH THEN WAS SEPARATED INTO THE TWO MAJOR COMPONENTS OF THE TANK. THE PUNCTURES WERE THEN RESEALED AND THE TANK REASSEMBLED USING TANK SEALANT AND NEW RIVETS. THIS REPAIR WAS VERY STRAIGHT FORWARD AND I AM FULLY CAPABLE OF MAKING IT. IT IS SIMILAR IN PROCESS TO OTHER ACFT. THE REPAIR WAS A TOTAL SUCCESS AND WAS REINSTALLED ON THE ACFT BY THEM. IT WAS THEN DECIDED BY THE LCL FLT SCHOOL THAT THEY WANTED A FORM 337 FILED SINCE THIS CONSTITUTES A MAJOR REPAIR. I ASKED THEM TO BRING ME THE ACFT MAINT MANUAL SO I COULD QUOTE THE NECESSARY REFS AND MAKE THE NECESSARY PAPERWORK. THE MAINT MANUAL MAKES NO PROVISION FOR THIS TYPE OF REPAIR. OBVIOUSLY I DID NOT CONSULT THE MANUAL PRIOR TO MAKING THE REPAIR. IT STATES THAT A TANK SHOULD BE SENT TO A 145 REPAIR STATION AUTH TO REPAIR THIS TYPE OF TANK. I DID NOT SEE ANYTHING SPECIAL ABOUT THE PROCESS OF REPAIRING THIS TANK WHEN I RECEIVED IT. ALL OF THE PROCS ARE CLEARLY OUTLINED IN AC43.13-1A TO MAKE SIMILAR TYPES OF REPAIRS, I THEREFORE SIMPLY DID THE REPAIR ASSUMING THAT IT WAS COMMON AND WOULD SURELY BE OUTLINED IN THE MAINT MANUAL. CALLBACK CONVERSATION WITH RPTR REVEALED THE FOLLOWING INFO: THE RPTR STATED THE REPAIR WAS REMOVING THE RIVETS AND RESEALING THE TANK AND ONLY AFTER THE REPAIR WAS COMPLETED DID THE QUESTION COME UP ABOUT THE REPAIR MANUAL REF TO TANK REPAIR. THE RPTR SAID IT WAS CONSIDERED A MAJOR REPAIR TO BE ACCOMPLISHED AT A CERTIFIED REPAIR STATION ONLY. THE RPTR STATED THE REGS ARE REALLY NOT CLR ON WHAT IS AND IS NOT A MAJOR REPAIR. THE RPTR SAID NO CONTACT HAS BEEN MADE BY THE FAA.

Data retrieved from NASA's ASRS site as of July 2007 and automatically converted to unabbreviated mixed upper/lowercase text. This report is for informational purposes with no guarantee of accuracy. See NASA's ASRS site for official report.