Aviation Investigation Final Report

Location: Las Vegas, Nevada Incident Number: ENG22FA009

Date & Time: February 4, 2022, 01:19 Local Registration: N817SY

Aircraft: Boeing 737-8K2 Aircraft Damage: Minor

Defining Event: Landing gear collapse Injuries: 56 None

Flight Conducted Under: Part 121: Air carrier - Scheduled

Analysis

Upon retracting the landing gear after takeoff, the flight crew received a right main landing gear
(RMLG) red position indicator light, indicating that the RMLG was not in the up and locked
position. The crew elected to return to the departure airport and the RMLG red indicator light
remained illuminated until the crew selected the gear DOWN position for landing. During the
landing roll, the RMLG collapsed, resulting in minor damage when the right engine impacted
the runway. It is likely that the RMLG was partially fractured after takeoff which prevented it
from retracting to the up and locked position.

Examination of the RMLG revealed that the outer cylinder fractured through a tooling hole.
Examination of the fracture revealed the presence of fatigue cracking that initiated at the
intersection of the tooling hole inner diameter and the outer cylinder inner diameter. Four areas
of arc burn damage were identified in the tooling hole area, two of which were at the crack
initiation sites. Cadmium identified at the intergranular separation initiation sites indicated the
crack initiated due to liquid metal embrittlement by cadmium at the arc burn locations before
propagating in fatigue.

The RMLG was last overhauled about 10 years before the incident, during which the outer
cylinder was replated with cadmium after repair. It is likely that the arc burning in the tooling
hole area was caused by a hand-held stylus cadmium plating operation performed in the
tooling hole when the stylus (anode) made contact with the outer cylinder (cathode), initiating
an arc. A nonconductive sleeve normally installed on the anode was either not present or
deteriorated, allowing physical contact between the anode and cathode.

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Probable Cause and Findings
The National Transportation Safety Board determines the probable cause(s) of this incident to be:

The fatigue failure of the right main landing gear initiated by liquid metal embrittlement by
cadmium at arc burn locations in the outer cylinder tooling hole area. The arc burns were likely
the result of operator error during stylus cadmium plating operations during overhaul.

Findings
Aircraft Main landing gear - Fatigue/wear/corrosion
Personnel issues Scheduled/routine maintenance - Maintenance personnel

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Factual Information

History of Flight
Landing-landing roll Landing gear collapse (Defining event)

On February 4, 2022, about 0119 Pacific standard time (PST), Sun Country Airlines flight 110, a
Boeing 737-8K2, N817SY, sustained minor damage when it suffered a right main landing gear
(RMLG) collapse during landing at Harry Reid International Airport (LAS), Las Vegas, Nevada.
The 50 passengers and 6 flight crew members were not injured. The airplane was operated as
a Title 14 Code of Federal Regulations Part 121 scheduled domestic passenger flight.
Sun Country flight 110 departed LAS about 0040 PST enroute to Minneapolis, Minnesota.
According to crew statements, after takeoff the crew moved the landing gear handle to the UP
position to retract the landing gear, and subsequently received a red position indicator light for
the RMLG. The crew engaged the autopilot while they consulted the GEAR DISAGREE checklist.
They placed the landing gear handle in the OFF position and the autopilot began retrimming
the airplane, so they placed the handle back in the UP position. Subsequently, the crew
reported hearing a loud sound from aft of the cockpit, so they declared an emergency and
returned to LAS. During the approach, the crew moved the landing gear handle to the DOWN
position and received three green position indicator lights for the landing gear. Shortly after
touching down on the runway, the RMLG collapsed. The airplane rolled right, and the right
engine impacted the runway. The crew stopped the airplane on the runway and the passengers
and crew deplaned using airstairs to a waiting bus. The airplane was then moved to the ramp.
Flight data recorder (FDR) data showed that the airplane lifted off about 0040:28 and the
landing gear were commanded to the UP position about 3 seconds later. The left main landing
gear (LMLG) and nose landing gear (NLG) began retracting about 1 second later. The RMLG
began retracting about 6 seconds after being commanded. The red landing gear position
indicator lights for all three landing gear illuminated when they were commanded to the up
position indicating the landing gear were in transit. The LMLG and NLG indicator lights
changed to green about 8 seconds later, when they were in the up and locked position. The
RMLG indicator light remained red, indicating that the RMLG was not in the up and locked
position during the flight. The landing gear were commanded to the DOWN position about
0114:37 and all three were in the down and locked position about 11 seconds later with green
indicator lights illuminated for each. The airplane touched down with the LMLG about 0118:56,
followed by the RMLG less than one second later. The RMLG collapsed about 4 seconds after
it touched down and the red position indicator light illuminated. The airplane came to a stop on
the runway about 0119:27.

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 Pilot Information
Certificate: Airline transport Age: 38
Airplane Rating(s): Single-engine land; Multi-engine Seat Occupied: Left
land
Other Aircraft Rating(s): None Restraint Used: 5-point
Instrument Rating(s): Airplane Second Pilot Present: Yes
Instructor Rating(s): Airplane multi-engine; Airplane Toxicology Performed:
single-engine; Instrument airplane
Medical Certification: Class 1 Without Last FAA Medical Exam: February 3, 2021
waivers/limitations
Occupational Pilot: Yes Last Flight Review or Equivalent: May 31, 2021
Flight Time: 4869 hours (Total, all aircraft), 1471 hours (Total, this make and model), 3195 hours (Pilot In
Command, all aircraft), 87 hours (Last 90 days, all aircraft), 23 hours (Last 30 days, all aircraft),
0 hours (Last 24 hours, all aircraft)

Co-pilot Information
Certificate: Airline transport Age: 44
Airplane Rating(s): Single-engine land; Multi-engine Seat Occupied: Right
land
Other Aircraft Rating(s): None Restraint Used: 5-point
Instrument Rating(s): Airplane Second Pilot Present: Yes
Instructor Rating(s): Airplane single-engine; Instrument Toxicology Performed:
airplane
Medical Certification: Class 1 Without Last FAA Medical Exam: May 13, 2021
waivers/limitations
Occupational Pilot: Yes Last Flight Review or Equivalent: January 17, 2022
Flight Time: 13141 hours (Total, all aircraft), 74 hours (Total, this make and model), 1243 hours (Pilot In
Command, all aircraft), 74 hours (Last 90 days, all aircraft), 52 hours (Last 30 days, all aircraft),
0 hours (Last 24 hours, all aircraft)

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 Aircraft and Owner/Operator Information
Aircraft Make: Boeing Registration: N817SY
Model/Series: 737-8K2 Aircraft Category: Airplane
Year of Manufacture: 2001 Amateur Built:
Airworthiness Certificate: Transport Serial Number: 30392
Landing Gear Type: Retractable - Tricycle Seats: 195
Date/Type of Last February 3, 2022 Continuous Certified Max Gross Wt.: 174200 lbs
Inspection: airworthiness
Time Since Last Inspection: Engines: 2 Turbo fan
Airframe Total Time: 68382 Hrs as of last Engine Manufacturer: CFM INTL.
inspection
ELT: C126 installed, not activated Engine Model/Series: CFM56 SERIES
Registered Owner: Sun Country Airlines, Inc. Rated Power: 27300 Lbs thrust
Operator: Sun Country Airlines, Inc. Operating Certificate(s) Flag carrier (121),
Held: Supplemental
Operator Does Business As: Operator Designator Code: SCNA

The RMLG assembly, P/N 161A1100-40, S/N MAL02520Y1240, was delivered new on a 737-
800 on December 2, 2002. The RMLG was removed from the airplane in October 2007 after
accruing 17,381 hours and 12,122 cycles since new and installed on a different airplane. The
RMLG was removed in January 2012 for overhaul after accruing 32,780 hours and 20,995
cycles since new. The overhaul of the RMLG was performed by TAP Maintenance &
Engineering, Brazil, and was completed in March 2012. The overhaul included the stripping of
all paint, chrome, nickel, and cadmium plating, inspection of the outer cylinder assembly,
repair, and the application of new plating and paint. There were no discrepancies noted around
the tooling hole in the overhaul documentation. The NTSB attempted to obtain more
information on the plating process used during the overhaul, but TAP stopped performing
landing gear overhauls in 2019 and the facility was closed in early 2022. The RMLG was
installed on a different airplane in July 2012 before being removed in August 2013 after
accruing 36,199 hours and 23,896 cycles since new. It was then installed on a different
airplane. The RMLG was removed in January 2020 after accruing 51,697 hours and 37,550
cycles since new. Aerospace Rotables, Inc. had the RMLG inspected and recertified per the
latest Component Maintenance Manual (CMM) revision by Seman, Peru, in October 2020. The
RMLG was cleaned, inspected, and repainted by Seman and compliance with all ADs and SBs
was verified. The RMLG was installed on the accident airplane in November 2020. The RMLG
had accrued 54,509 hours and 38,491 cycles since new (17,496 cycles since overhaul) at the
time of the accident. The most recent lubrication of the RMLG in accordance with AD 2019-01-
03 was performed on February 1, 2022.

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Overhaul procedures for the RMLG outer cylinder are published in the Boeing CMM, Chapter
32-11-12. Typically, an outer cylinder would be stripped of all paint, primer, and existing
cadmium plating before undergoing inspection and repair. Nickel and chromium plated
surfaces may remain on the part if they are of acceptable condition for return to service. Once
the inspection and repair are complete, the outer cylinder would have nickel and/or chromium
plating applied in specific seal areas if they had been previously removed, while the remainder
of the part would have cadmium plating applied per CMM requirements for corrosion
resistance. Finally, the outer cylinder would have primer and paint applied.
Cadmium plating is applied using an electroplating process where the outer cylinder is
submerged in a tank of electrolyte plating solution with an electrical current supplied through
the outer cylinder that acts as the cathode and installed anodes in the tank. For parts with
complex geometries such as the outer cylinder, auxiliary anodes must be designed and placed
in such a way to ensure that the cadmium plating is uniform and of the desired thickness
throughout the part. Alternatively, areas of complex geometry such as the tooling hole can be
cadmium plated using a stylus or brush plating process. In this process, the part is still acting
as the cathode while a technician inserts a portable handheld anode into the hole. The anode
stylus, which is saturated with plating solution, would be manipulated around the hole to
ensure plating is applied in all areas. Typically, the stylus would be wrapped in an electrically
non-conductive sleeve, which prevents the anode from making direct physical contact with the
surface of the part being plated (cathode). In cases where the sleeve is deteriorated or not
installed, physical contact between the anode and cathode can result in an electrical arc
between the stylus and outer cylinder. An electric arc can produce high currents and heat
sufficient to cause localized melting or other degradation of the base metal material
properties.

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 Meteorological Information and Flight Plan
Conditions at Accident Site: Visual (VMC) Condition of Light: Night
Observation Facility, Elevation: KLAS,2180 ft msl Distance from Accident Site: 1 Nautical Miles
Observation Time: 00:56 Local Direction from Accident Site: 256°
Lowest Cloud Condition: Clear Visibility 10 miles
Lowest Ceiling: None Visibility (RVR):
Wind Speed/Gusts: 9 knots / Turbulence Type None / None
Forecast/Actual:
Wind Direction: 20° Turbulence Severity N/A / N/A
Forecast/Actual:
Altimeter Setting: 30.46 inches Hg Temperature/Dew Point: 4°C / -11°C
Precipitation and Obscuration: No Obscuration; No Precipitation
Departure Point: Las Vegas, NV (LAS) Type of Flight Plan Filed: IFR
Destination: Minneapolis, MN (MSP) Type of Clearance: IFR
Departure Time: 00:19 Local Type of Airspace: Class B

Airport Information
Airport: Harry Reid International Airport LAS Runway Surface Type: Concrete
Airport Elevation: 2181 ft msl Runway Surface Condition: Dry
Runway Used: 26R IFR Approach: ILS;Visual
Runway Length/Width: 14515 ft / 150 ft VFR Approach/Landing: Straight-in

Wreckage and Impact Information

Crew Injuries: 6 None Aircraft Damage: Minor
Passenger 50 None Aircraft Fire: None
Injuries:
Ground Injuries: Aircraft Explosion: None
Total Injuries: 56 None Latitude, 36.076362,-115.14199(est)
Longitude:

Examination of the airplane after the event revealed that the RMLG outer cylinder was
fractured around the circumference between the forward and aft trunnions through the bung
hole. (see Figure 1.) The bung hole is a tooling locator hole used during the manufacture of the
outer cylinder.

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Figure 1. Fractured RMLG installed on incident airplane (photo provided by Boeing)
The fractured portion of the RMLG was removed from the airplane and examined at the Boeing
Equipment Quality Analysis Laboratory under NTSB supervision. The examination revealed the
presence of primary and secondary origin areas on opposite sides of the tooling hole where
the inner diameter of the tooling hole and the inner diameter of the outer cylinder intersect.
(see Figure 2.) Scanning electron microscope (SEM) examination of the origin areas showed
fracture features consistent with intergranular separation and the presence of pure cadmium
on the grain faces and grain boundaries that extended to a depth of about 0.02 inch. Beyond
this depth, the fractures transitioned to transgranular slow growth fatigue cracking that

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propagated to a depth of about 0.42-inch on the primary side and 0.07-inch on the secondary
side. The remaining area of fracture exhibited features consistent with ductile separation.

Figure 2. RMLG tooling hole fracture origins (photo provided by Boeing)

The aft fracture piece was stripped of all paint, primer, and plating, revealing the presence of
four spherical shaped anomalies, each about 0.1-inch in diameter, at the intersection of the
tooling hole inner diameter and the outer cylinder inner diameter. (see Figure 3.) Two of these
anomalies were coincident with the primary and secondary origins. The spherical anomalies
were consistent with areas of base metal heat damage due to electrical arcing. Microstructure
examination, hardness testing, and nital etching of the spherical areas showed the presence of
undertempered martensite and overtempered martensite, which confirmed the base metal
heat damage.

Page 9 of 11 ENG22FA009
Figure 3. Arc burns on RMLG tooling hole (photo provided by Boeing)
In the areas away from the arc burns, the protective finishes were in accordance with Boeing
requirements, the material was consistent with 4340M stainless steel, and the hardness was
consistent with the 275-300 ksi heat treat condition.

Page 10 of 11 ENG22FA009
 Administrative Information
Investigator In Charge (IIC):
Additional Participating
Persons:
Original Publish Date:
Last Revision Date:
Investigation Class:
Note:
Investigation Docket:
Crookshanks, Clinton
Jessica Winter; Sun Country Airlines; Minneapolis, MN
Dave Keenan; FAA AVP-100; Washington, DC
Nate Williams; Boeing; Seattle, WA
Chris Heck; ALPA; Ashburn, VA
Paul Spurgeon; Sun Country Airlines; Minneapolis, MN
March 21, 2023
Class 3
https://data.ntsb.gov/Docket?ProjectID=104596

The National Transportation Safety Board (NTSB) is an independent federal agency charged by Congress with
investigating every civil aviation accident in the United States and significant events in other modes of transportation—
railroad, transit, highway, marine, pipeline, and commercial space. We determine the probable causes of the accidents
and events we investigate, and issue safety recommendations aimed at preventing future occurrences. In addition, we
conduct transportation safety research studies and offer information and other assistance to family members and
survivors for each accident or event we investigate. We also serve as the appellate authority for enforcement actions
involving aviation and mariner certificates issued by the Federal Aviation Administration (FAA) and US Coast Guard, and
we adjudicate appeals of civil penalty actions taken by the FAA.

The NTSB does not assign fault or blame for an accident or incident; rather, as specified by NTSB regulation,
“accident/incident investigations are fact-finding proceedings with no formal issues and no adverse parties … and are
not conducted for the purpose of determining the rights or liabilities of any person” (Title 49 Code of Federal Regulations
section 831.4). Assignment of fault or legal liability is not relevant to the NTSB’s statutory mission to improve
transportation safety by investigating accidents and incidents and issuing safety recommendations. In addition,
statutory language prohibits the admission into evidence or use of any part of an NTSB report related to an accident in a
civil action for damages resulting from a matter mentioned in the report (Title 49 United States Code section 1154(b)). A
factual report that may be admissible under 49 United States Code section 1154(b) is available here.

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