EI1588 vs EI1598 - INTOPLANE JET FUEL

FILTRATION TECHNOLOGIES. By George Garcia

Comparing Apples and Oranges

When a fire is heading in your direction, which is the better solution?

a) A Firewall that would impede any fire from entering your area, or
b) A smoke alarm that would signal that you have smoke in your area and once
this occurs the fire brigade be alerted.
It is quite evident that the safest and thus the best option would be to have a firewall
to protect you and your belongings.
OSHA´s prime recommendation when running a risk assessment is to try to
“eliminate the hazard” and the firewall does just that and is therefore the preferred
solution.
An analogous situation is currently happening with the prevention of water and
debris from entering an aircraft and two completely different solutions are competing
for the task of dispensing clean and dry fuel from a fueling truck to an aircraft.
The competing technologies for this application are:
a) EI1588 – Filter Particulate and Water Barrier
EI1588 filtration is the equivalent to the Firewall and impedes water and debris from
entering the aircraft. It is the safest solution because it acts directly on the problem
by removing water from the fuel stream and thus eliminating this risk to the aircraft.
This solution does not depend on any secondary apparatus to protect the aircraft and
will either remove the contaminants or impede the fueling process if free water or dirt
is present in the fuel stream.
 b) EI1598 / EI1599 – Sensor based water detection coupled to EI1599 Filter
element

EI1598 is an electronic sensor-based solution and specifies what would be equivalent

to a smoke detector in our early example. The specification outlines in detail the
necessary performance for a water sensing device on to be installed on the filter
outlet. The idea is that with a sensing device in the fuel line, the fueling process can be
interrupted if water above a given level is detected in the fuel stream.

EI1599 specifies the filter element responsible for the removal of particulate matter
from the fuel stream. My conclusion is that the performance in removal of particulate
matter will most likely will be equivalent in both technologies so this will not be further
discussed.

The focus is therefore WATER and how to prevent it from entering the aircraft.
KEY ISSUE: On a fueling truck, should water be removed by filtration or should we
entrust this to an onboard detection system based on a water detector probe?

Historically water has been removed from Jet Fuel by Filter Water Separators (FWS),
API-1581 or by means of water absorbing elements better known as monitor elements
under API-1583. Worldwide, a good combination of the two technologies has been
widely employed, with FWS filters being installed in fixed installations and monitor
elements on mobile equipment. This combination greatly improved safety, with FWS
filters stripping solid contaminants and water in fuel farm and monitor elements on
the trucks removing trace amounts of solids and water and also providing an added
layer of safety because of its insensitivity to surfactants.

In widespread use for over 40 years, monitor elements provide a highly effective
means of protecting the aircraft from solid contaminants and water. During this
period thousands of aircraft were protected from water contamination by monitor
element fuel flow blockage. Notwithstanding the elements were not perfect and
several incidents involving SAP migration occurred during this time frame. In order to
address these issues, the construction norm API1583 underwent seven revisions. In
particular, the last two revisions addressed SAP migration and introduced a 15 psi DP
maximum operating differential pressure.

As a result of this evolution, most users were quite satisfied with the filtration
technology until the report IATA Super-absorbent Polymer (SAP) Special Interest Group
– Data summary and proposed roadmap was published by a study group of the
technology. The report lists several incidents between 2010-2017, a comparative
monitor element test for three manufacturers and the studies were conducted at the
Shell UK lab. The report condemned the use of monitor elements based on several
known incidents. The report is skewed because:
 a) Manufacturers were not named. Report listed the manufacturers as A, B, C.
Manufacturer “A” failed miserably producing results up to 100 times worse
than the other two competitors.

Until this time, users in the industry treated the elements as equal and
essentially as a commodity item. Most purchased the least expensive element,
because supposedly all had similar performance, and all were built to the same
norm. Easy to tell this was untrue.

b) There is no mention if the failed elements of the 6th edition were ever
inspected to the norm. It is unexplainable why no public investigation was
conducted for the reason that the element, built to the same norm, had such
poor results in the tests. I personally doubt this. Were the elements
constructed in similar fashion to the qualified elements? Were changes
introduced to the elements after qualification?

Before disqualifying the technology altogether, a better understanding of what

was wrong with the Manufacturer “A” elements was in order. If the elements
did not meet the 6th edition requirement the manufacturer should have been
held responsible for selling out of spec product and held accountable for this
failure instead of blaming the technology.

c) All reported incidents are correct, but no mention is made as to element

manufacture / edition involved nor differential pressure the elements were
subjected to. The SAP migration problem was addressed throughout the 40
years of evolution and, in particular, with the introduction of the sixth edition.

With manufacturer B or C and the mandatory 15 psi shutdown, the last

reported incident would not have occurred.
The IATA report had the objective to support a decision to discontinue the use of
monitor element technology and replace it with something new without any further
discussion. Unfortunately, this appears to be the case.
Products evolve constantly. New technologies are introduced, and all products have a
life cycle, and it would be natural that at some given time the filtration technology
evolve and replace the monitor elements. What is not natural is for a product,
deemed safe for use for 40 years, be discontinued in short notice while leaving
thousands of users without an adequate replacement solution.
At the end of this year the Energy Institute (EI) will remove its endorsement to the
current EI1583 monitor element construction norm leaving users without a new
approved interchangeable filtration element alternative and practically obliging users
to adopt the only EI approved alternative of a sensor based technology despite this
never be field tested in wide scale environment and in total disconsideration to the
enormous difficulties in implementing a viable solution for trucks currently equipped
with monitor vessels.
Simultaneously, EI is dragging its foot to approve new filter element, notably the new
Velcon CDFX water barrier elements that has no SAP and is currently the only drop in
replacement solution for a 2” diameter element in existing monitor filter vessels.
Tests already prove that the new elements outperform existing monitor elements of
the same manufacturer in use all over the world but, despite these results, EI insists on
a slew of additional field tests that appear to never end. If SAP is such a danger, the
delay in approval of the new alternative element is unexplainable and disregards
passenger safety and limit the options for a solution to one.
Please never forget that filters are the equivalent to the Firewall in the early fire
example but even better as they continually strip water from fuel even when treating
fuel under the specified water content limit.
Filtration should always be considered the safest and most proper solution to water
and particle contamination removal in fuel.
From an outsider point of view, the delays in the approval process appear very
strange given the urge to eliminate SAP, the upcoming deadline for monitor element
removal and the lack of approved alternatives other than the FAUDI sensor
technology.
As to the Sensor Based Solution the drawbacks to its adoption are enormous:
a) Price – The sensors are awfully expensive. They will cost users much more
than what they currently pay for filtration.
b) Calibration – The units must be periodically calibrated and, up to now, the
solution appears to require they be shipped back to the factory in Germany. I
have no knowledge of any other equipment aboard a fuel truck to require
factory calibration. This will become a nightmare to implement and may not
even be viable in many countries because of the difficulty of getting products in
and out thru customs.
c) The solution is analogous to the Smoke Detector and will only provide an
alarm signal to the truck that water content in the fuel stream is above a
certain level. This signal must be tied into the truck system in order to shut
down the fuel process typically by acting on the deadman valve. If anything is
wrong with sensor, the wiring, or the deadman system, the fuel will continue to
flow to the airplane.
d) This system does not remove water from the fuel stream – It only signals the
existence of water until an upper level is reached when a signal to shut down
the system is triggered. When a shutdown occurs, a considerable amount of
fuel with water content lower than the trigger point may have already been
loaded to the airplane. Up until now filter elements were in great part capable
 of maintaining water content levels way below 30 ppm high water trigger level.

e) We already have reports that the fuel sensors are incorrectly measuring the
water content in the fuel stream in different scenarios. This raises an
especially important safety question as to how reliable and safe this system in
service is.

f) SENSORS DON’T ELIMINATE THE RISK; THEY ONLY MANAGE THE RISK. Frankly,
managing risk, may be an alternative for very well-run fueling operations, with
well trained personnel, great maintenance crews, low turnover. I wonder how
airports around the world fall into this category today.
Bottom line is that Sensor Based Technology is a great new and promising technology
but, considering the alternatives, should not be deemed the safest solution to prevent
water from entering an aircraft. For safety sake, preference should be given to filter
based technologies that either block or somehow remove water during the last stage
of filtration on the fuel truck. Water should never be allowed to overcome the filter
vessel.
Airlines, in particular, should be very keen in specifying what is safest for the aircraft
and passengers. Just think about what would happen if an accident happens due to
contaminated fuel and compare the difficulty of assessing cause when using a barrier
or a sensor-based system.
Also, of grave concern, is the influence of big operators setting and implementing rules that
ignore the needs of the much larger number of small operators. How can a small airport be
compared with a massive one?

My intent in publishing this essay is to spur a wider debate that has been lacking on this
matter. Very important investment and operational decisions have to be made to replace
monitor elements. Airlines should clearly evaluate the risks and drawbacks of each technology
and should select the safest solution be it the continued use of high quality monitor elements,
new EI 1588 approved elements or EI1598 sensor based technology.

I trust that operators and airlines will consider ALL the alternatives and select for themselves
the safest solution for their fleet of trucks and airplanes.

Your comments regarding this subject are very welcome.

Eng. George Garcia
Avi Mach Equipamentos e Pecas BRAZIL
george@avimach.com.br
Tel +55 11 4055-4211