Continental Airlines

Continental Airlines PO Box 4623 HQJSE Houston, TX 772104607 14-Jan-08 To: Ms. Kathrine Rask Aerospace Engineer, Propulsion Branch FAA ANM-140S, Seattle ACO 1601 Lind Avenue SW Renton, Washington 98057-3356 Subject: Docket No. FAA-2007-28348, Directorate Identifier 2007-NM-060-AD This correspondence provides comments regarding Docket No. FAA-2007-28348, Directorate Identifier 2007-NM-060-AD, which proposes to mandate the actions specified by the original release of Boeing Alert Service Bulletin (ASB) 737- 57A1279. This alert service bulletin was issued as a result of the safety assessments conducted by Boeing under SFAR-88, Fuel Tank System Fault Evaluation Requirements. ASB 737-57A1279 addresses the concerns of electrical arching inside the fuel tank that can be caused by wiring shorts at the certain clamp locations and certain wire bundles that are routed within the fuel tank boundary structure. Accomplishing these requirements of this alert service bulletin will help to prevent possible sources of ignition in and around the fuel tanks. An ignition source inside the fuel tanks or at the fuel tank boundary structure could result in a fire or an explosion. Continental Airlines concurs with the proposed rule to mandate the aforementioned alter service bulletin to ensure a higher level of safety for the B737NG fleet. We are in the process of incorporating the change into our B737-700/800/900 aircraft during scheduled heavy maintenance opportunities. We have not accomplished the modification to date, but based on our experience, we would like to address the long-term issues regarding of this proposed ruling. Beyond the scope of the proposed ruling, Continental Airlines is concerned that not enough attention is being given to ensure the specific changes detailed by the alert service bulletins are preserved for the long-term operation of the B737NG fleet. This includes all airplanes subsequent to those affected by the proposed ruling. This proposed ruling, in effect, mandates a one-time change to implement the protection against ignition sources on the affected airplanes. Subsequent airplanes, including new deliveries entering service, already have this requirement incorporation in production. However, other than the service bulletins and some generic information found in the 737NG Maintenance Planning Data, there are no other published ?maintenance? documents currently available to show each specific requirement as detailed by ASB 737-57A1279. Information detailed by this alert service bulletin must be made available in manuals that are routinely used by maintenance personnel. This will prevent inadvertent reversal of the implemented changes that can lead to the violation of the proposed ruling, in addition to compromising the higher level of safety intended for the fleet. We have expressed our concerns to Boeing regarding this matter. Boeing is currently reviewing different options in making the information readily available for the purpose of routine maintenance environment. Continental Airlines requests the FAA to review the above discussions. We urge the FAA to consider the long-term effect under the ruling if the information required to preserve the expected level of safety is no available, or is inadequate, to alert maintenance personnel performing routine services on this fleet. For further questions regarding this matter, please feel free to contact me at the information listed below. Sincerely, Adam Brandon B737NG Structures Engineering Continental Airlines, Inc. P: 713-324-3913 F: 713-324-7703 e-mail: adam.brandon@coair.com cc: D. Pohlmeyer J. Moses M. Eldred DOT DMS File