Japan Airlines International

JAL would like to propose the followings. 1. The NPRM states that AMM 28-22-00 and Boeing Task Card 28-018-02 are the approved method to comply with the AD. But both AMM 28-22-00 and Boeing Task Card 28-018-02 include two tasks. One is "Engine Fuel Suction Feed - Operational Test", and the other is "Pressure Leak Check of the Fuel Lines and Fittings". JAL has been currently performing the operational check of the engine fuel suction feed system in accordance with Maintenance Planning Document, Item Number 28-22-00-5G. MPD calls out AMM task 28-22-00-725-575 "Engine Fuel Suction Feed - Operational Test"and AMM task 28-22-07-796-001"Pressure Leak Check of the Fuel Lines and Fittings" at 1 C interval. Two tasks are equivalent procedures and each one of them would satisfy the operational check requirement of this new AD. Operators would be able to make a selection from the two procedures. JAL requests the FAA to consider clarifying if the operator can choose each one of the two tasks to comply with the new AD. 2. The AMM 28-22-00 and Boeing Task Card 28-018-02 contain two tasks. To avoid misunderstanding of requirement of this AD, the new AD had better call out the AMM Task Number or aforementioned MPD Item Number as examples. JAL requests FAA the new AD to specify the exact AMM Task Number or aforementioned MPD Item Number as examples for AD comliance . 3. JAL believe this requirements should not be adressed as AD but CMR task.