KLM Royal Dutch Airlines - SPL/CI Fleet Services

NPRM 2007-NM-351-AD. Paragraph (f) states: "Within 7,500 flight hours after the effective date of this AD, perform an operational test of the engine fuel suction feed of the fuel system, and perform all related testing, as applicable, before further flight, according to a method approved by the Manager, Seattle Aircraft Certification Office (ACO), FAA. One approved method is the operational test in Section 28-22-00, titled "Engine Fuel Feed System--Maintenance Practices,'' of the Boeing 737- 300/400/500 Maintenance Manual (MM); and Boeing 737-300/400/500 Task Card B28-22-00-2B, titled "Engine Fuel Suction Feed-- Operational Test,'' dated July 12, 2006. Repeat the operational test thereafter at intervals not to exceed 7,500 flight hours. Thereafter, except as provided in paragraph (g) of this AD, no alternative procedure or repeat test intervals will be allowed." Comment: 1) If an aircraft does not pass the operational test of the engine fuel suction feed a tank entry is required. This has most likely an impact on the currently scheduled downtime requirements for the C-checks. Therefore, KLM requests the FAA: to extend the deadline of the initial test from 7,500 flight hours after the effective date of the forthcoming AD to 8,000 flight hours or 2 C-check after the effective date of the forthcoming AD. to extend the interval of the repetitive test from 7,500 flight hours to 8,000 flight hours or 2C. 2) KLM requests the FAA to consider addition of the operational Fuel Feed Manifold Air Pressure Leak Check Procedure per AMM 28-22-15 as alternative test. This alternative test is allowed by AMM 28-22-00.