Continental Airlines, Inc.

Docket Operations U.S. Department of Transportation M-30 West Building Ground Floor, Room W12-140 1200 New Jersey Avenue SE., Washington, DC 20590-001 Subject: B757 Engine Fuel Feed System, Fuel Boost Pump Wire Changes ? Proposed Rule Reference: A/ Rules Docket No. FAA-2007-0175 B/ Boeing Service Bulletins 757-28-0095 & 757-28-0096 C/ NPRM Docket No. 2007-NM-184-AD D/ Picture, AC0880, LH FWD boost pump connector Dear Sir or Madam: In response to the ref. /A/ FAA?s proposed rule, requiring the affected boost pump wire changes and other specified actions, Continental Airlines has reviewed the ref. /C/ NPRM and related documents and the comments below are submitted for your consideration. Continental Airlines is currently implementing the wire modifications in our 757 fleets in accordance with Boeing S/B 757-28-0095 and 757-28-0096. In reference to the 757-200 fleet and ref. /B/ service bulletin number 757-28-0095, figure 2, AC0880, LH FWD fuel boost pump wiring change, it would have been easier and more appropriate the modification to utilize one of the open holes in the panel, install a new connector and transfer only the pump wires to the new connector instead of splicing the wires as shown in the S/B for this location. See in the ref. /D/ attached picture the upper and lower connector available locations for the new connector installation and the removed wires from the existing connector. Also, the splice locations for the LH AFT and RH AFT boost pumps as shown in the ref. /B/ service bulletin affected figures are incorrect and the splices cannot be accomplished in those areas. Boeing has been advised and they are working in the ref. /B/ service bulletin revisions. Continental recommends that the reference /B/ service bulletins to be revised with the proper alternate rework instructions for the above mentioned discrepancies prior to the ref. /C/ NPRM becoming a 14 CFR Part 39- Airworthiness Directive (AD). If the ref. /C/ NPRM becomes an AD without the necessary changes in the affected sections been implemented in the ref. /B/ bulletins revision 1 release, then an alternate means of compliances for this AD per 14 CFR 39.19 procedures would be required for each airplane that, any of the above discrepancies are found and the alternate work instructions are applied. Thank you for the opportunity to comment on this subject. Please feel free to contact me if you have further questions on this subject. Sincerely, George Zombanakis Master Systems Engineer