Narrative:

Upon starting my interior inspection on our B727 an FAA inspector arrived and informed us we were to receive an en route check on our flight from dia to sfo. After checking his credentials I went back to my duties and completed my inspection. There were a couple of instances that the FAA inspector asked questions, but once we began our checklist procedures he sat back and did not ask any more questions. At this stage is where the beginning of the problem begins. Our fuel load was such that we had a total of 36600 pounds of fuel on board (#1 tank 11600 pounds, #2 tank 13400 pounds, #3 tank 11600 pounds). Our fuel procedure is such that if the #2 tank exceeds fuel by any amount of the fuel in #1 and #3 tanks, we must burn #2 fuel to all engines until it reaches the amount in #1 and #3 tanks. The problem with this procedure is that during a prolonged 2 or 3 engine taxi, the fuel in the #2 tank can be just above or even equal to that in the other tanks. This potentially could cause the fuel in the #2 tank to be burned below the even point and potentially could exceed the 2000 pound maximum limit below #1 and #3 tanks imposed by boeing and our airline. After a brief discussion with the captain, I elected to burn tank to engine until after the second segment climb was started to avoid this potential problem, the captain concurred. At no time did the FAA inspector say anything about this nor did he involve himself in the conversation. The rest of the checklist was completed and the start, taxi, and takeoff were accomplished without incident. After flap retraction, and into the second segment climb (approximately 2000 ft AGL) I began to burn all engines from the #2 tank in order to balance the #2 tank with tanks #1 and #3. As I began to do this I notified the captain and he concurred. After approximately 5-7 mins the fuel in the #2 tank equaled that in #1 and #3 tanks and the tank to engine fuel procedure was applied. Once again I notified the captain of the fuel change and he concurred. This ends any fuel changes for the rest of the flight, and any problems. After parking at the gate the FAA inspector gave us our debrief. He was a bit confused at first as to why I had been burning the #2 tank down after takeoff, but then realized the fuel load was such that that was required by procedure. He then commented that my procedure on the fuel panel management was incorrect and if I knew the procedure. I explained to him what the procedure was and the reasoning behind the non-standard way I set the fuel panel. I further explained of the potential for exceeding aircraft limits and the problems that would be associated with that. All of the points explained were agreed upon by the FAA inspector and he said that he agreed with me and would do it that way himself, but that other inspectors might find fault with it and thus violate me and my crew. With that he said not to worry that no fine or violation would be levied. My summary of this incident can only be given by a question: at what point do pilots utilize sound judgement, based on knowledge and experience, over that of an established procedure that is developed to cover all sits? This is an instance where trying to avoid a potential structural problem does not supersede standard operating procedure, yet the procedure and the FAA is inflexible to allow for pilots to avoid a problem by using sound judgement and knowledge of their aircraft. The only way to correct this problem is to change the procedure and the FAA certification to allow for this type of irregularity that occurs often in line operations.

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Original NASA ASRS Text

Title: SO OF A B727 FAILED TO FOLLOW THE MANUFACTURER'S FUEL MGMNT OPERATING PROC FOR ADJUSTING THE FUEL TANK WT WHEN THE FUEL IN #2 TANK EXCEEDS THE AMOUNT IN THE #1 OR #3 TANK.

Narrative: UPON STARTING MY INTERIOR INSPECTION ON OUR B727 AN FAA INSPECTOR ARRIVED AND INFORMED US WE WERE TO RECEIVE AN ENRTE CHK ON OUR FLT FROM DIA TO SFO. AFTER CHKING HIS CREDENTIALS I WENT BACK TO MY DUTIES AND COMPLETED MY INSPECTION. THERE WERE A COUPLE OF INSTANCES THAT THE FAA INSPECTOR ASKED QUESTIONS, BUT ONCE WE BEGAN OUR CHKLIST PROCS HE SAT BACK AND DID NOT ASK ANY MORE QUESTIONS. AT THIS STAGE IS WHERE THE BEGINNING OF THE PROB BEGINS. OUR FUEL LOAD WAS SUCH THAT WE HAD A TOTAL OF 36600 LBS OF FUEL ON BOARD (#1 TANK 11600 LBS, #2 TANK 13400 LBS, #3 TANK 11600 LBS). OUR FUEL PROC IS SUCH THAT IF THE #2 TANK EXCEEDS FUEL BY ANY AMOUNT OF THE FUEL IN #1 AND #3 TANKS, WE MUST BURN #2 FUEL TO ALL ENGS UNTIL IT REACHES THE AMOUNT IN #1 AND #3 TANKS. THE PROB WITH THIS PROC IS THAT DURING A PROLONGED 2 OR 3 ENG TAXI, THE FUEL IN THE #2 TANK CAN BE JUST ABOVE OR EVEN EQUAL TO THAT IN THE OTHER TANKS. THIS POTENTIALLY COULD CAUSE THE FUEL IN THE #2 TANK TO BE BURNED BELOW THE EVEN POINT AND POTENTIALLY COULD EXCEED THE 2000 LB MAX LIMIT BELOW #1 AND #3 TANKS IMPOSED BY BOEING AND OUR AIRLINE. AFTER A BRIEF DISCUSSION WITH THE CAPT, I ELECTED TO BURN TANK TO ENG UNTIL AFTER THE SECOND SEGMENT CLB WAS STARTED TO AVOID THIS POTENTIAL PROB, THE CAPT CONCURRED. AT NO TIME DID THE FAA INSPECTOR SAY ANYTHING ABOUT THIS NOR DID HE INVOLVE HIMSELF IN THE CONVERSATION. THE REST OF THE CHKLIST WAS COMPLETED AND THE START, TAXI, AND TKOF WERE ACCOMPLISHED WITHOUT INCIDENT. AFTER FLAP RETRACTION, AND INTO THE SECOND SEGMENT CLB (APPROX 2000 FT AGL) I BEGAN TO BURN ALL ENGS FROM THE #2 TANK IN ORDER TO BAL THE #2 TANK WITH TANKS #1 AND #3. AS I BEGAN TO DO THIS I NOTIFIED THE CAPT AND HE CONCURRED. AFTER APPROX 5-7 MINS THE FUEL IN THE #2 TANK EQUALED THAT IN #1 AND #3 TANKS AND THE TANK TO ENG FUEL PROC WAS APPLIED. ONCE AGAIN I NOTIFIED THE CAPT OF THE FUEL CHANGE AND HE CONCURRED. THIS ENDS ANY FUEL CHANGES FOR THE REST OF THE FLT, AND ANY PROBS. AFTER PARKING AT THE GATE THE FAA INSPECTOR GAVE US OUR DEBRIEF. HE WAS A BIT CONFUSED AT FIRST AS TO WHY I HAD BEEN BURNING THE #2 TANK DOWN AFTER TKOF, BUT THEN REALIZED THE FUEL LOAD WAS SUCH THAT THAT WAS REQUIRED BY PROC. HE THEN COMMENTED THAT MY PROC ON THE FUEL PANEL MGMNT WAS INCORRECT AND IF I KNEW THE PROC. I EXPLAINED TO HIM WHAT THE PROC WAS AND THE REASONING BEHIND THE NON-STANDARD WAY I SET THE FUEL PANEL. I FURTHER EXPLAINED OF THE POTENTIAL FOR EXCEEDING ACFT LIMITS AND THE PROBS THAT WOULD BE ASSOCIATED WITH THAT. ALL OF THE POINTS EXPLAINED WERE AGREED UPON BY THE FAA INSPECTOR AND HE SAID THAT HE AGREED WITH ME AND WOULD DO IT THAT WAY HIMSELF, BUT THAT OTHER INSPECTORS MIGHT FIND FAULT WITH IT AND THUS VIOLATE ME AND MY CREW. WITH THAT HE SAID NOT TO WORRY THAT NO FINE OR VIOLATION WOULD BE LEVIED. MY SUMMARY OF THIS INCIDENT CAN ONLY BE GIVEN BY A QUESTION: AT WHAT POINT DO PLTS UTILIZE SOUND JUDGEMENT, BASED ON KNOWLEDGE AND EXPERIENCE, OVER THAT OF AN ESTABLISHED PROC THAT IS DEVELOPED TO COVER ALL SITS? THIS IS AN INSTANCE WHERE TRYING TO AVOID A POTENTIAL STRUCTURAL PROB DOES NOT SUPERSEDE STANDARD OPERATING PROC, YET THE PROC AND THE FAA IS INFLEXIBLE TO ALLOW FOR PLTS TO AVOID A PROB BY USING SOUND JUDGEMENT AND KNOWLEDGE OF THEIR ACFT. THE ONLY WAY TO CORRECT THIS PROB IS TO CHANGE THE PROC AND THE FAA CERTIFICATION TO ALLOW FOR THIS TYPE OF IRREGULARITY THAT OCCURS OFTEN IN LINE OPS.

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.