Japan Airlines

Dear Sirs JAL would like to propose the followings. 1. The NPRM states that AMM 28-22-00 and Boeing Task Card 28-022-04-01 are the approved method to comply with the AD. But both AMM 28-22-00 and Boeing Task Card 28-022-04- 01 include two tasks. One is "Engine Fuel Suction Feed - Operational Test", and the other is "Engine Fuel - Feed Manifold Air Pressure Leak Check". JAL has been currently performing the operational check of the engine fuel suction feed system in accordance with Maintenance Planning Document, Item Number 28-022-01. MPD calls out AMM task 28-22-00-710 "Engine Fuel Suction Feed - Operational Test"and AMM task 28-22-07-706-801 "Engine Fuel - Feed Manifold Air Pressure Leak Check" at 1 D interval. Two tasks are equivalent procedures and each one of them would satisfy the operational check requirement of this AD. Operators can make a selection from the two tasks. JAL requests the FAA to consider clarifying if the operator can choose one of the two tasks to comply with the AD. 2. The AMM 28-22-00 and Boeing Task Card 28-022-04-01contain two tasks. To avoid misunderstanding of requirement, JAL requests the FAA to specify the exact AMM Task Number or aforementioned MPD Item Number as examples for AD comliance. 3. Essentially, JAL believes this requirement should not be adressed as AD but CMR(Certification Maintenance Requirement) task. Regards, Takeo Asano Japan Airlines