Embraer

Subject: Embraer Position to NPRM Docket No. FAA-2008-1079; Directorate Identifier 2008-NM-116-AD Dear Sir or Madam: The EMB-145 SFAR 88 compliance demonstration was documented by Embraer in technical report 145-FU-016 “Fuel Tank Ignition Source Safety Assessment (SFAR 88 Compliance)”. This technical report provides guidance for the introduction of new maintenance tasks in the Critical Design Configuration Control Limitations (CDCCL) and in the Fuel System Limitations (FSL), necessary to preclude ignition sources in the fuel system, which is the subject addressed by NPRM Docket No. FAA-2008-1079. Embraer only comment is related to the required inspections referenced in TABLE 2 of the NPRM: (please refer to the attached file) It is important to clarify that a simple functional check of the fuel conditioning units as per MRB tasks 28-41-01-720-001-A00 and 28-41-04-720-001-A00, respectively applicable to the Fuel Conditioning Unit (FCU) and Ventral Fuel Conditioning Unit (VFCU), would not entirely address the unsafe condition. Further discussions between Embraer and the FCU manufacturer revealed that only a functional check of the safe-life features in conjunction with internal and external inspections would adequately address the possibility of ignition sources in the unit. On March 5, 2007 Parker revised their CMM 28-41-36 and included a “Functional Check of the Safe Life Features” in addition to the Functional Test already in place. Therefore Parker CMM currently presents two functional tests: - Functional Test of the Fuel Conditioning Unit; and - Functional Check of the Safe-Life Features. The Aircraft Maintenance Manual task procedures are being revised in order to address the functional check of the safe-life features, according to the latest revision of Parker CMM for FCU. Appendix 2 of MRB-145/1150, item A.2.5 will have tasks 28-41-01-720-001-A00 and 28-41-04-720-001-A00, respectively applicable to Fuel Conditioning Unit and Ventral Fuel Conditioning Unit, revised to have their descriptions renamed to specifically call for a Functional Check of the Safe-Life Features. Since the MRB tasks mentioned in TABLE 2 have to be renamed and the internal and external inspections are not addressed at all by the NPRM Embraer proposes to revise the TABLE 2 as follows: (please refer to the attached file) An alternative method of compliance with the first inspection requirements in the proposed TABLE 2 above is the incorporation of Parker Service Bulletin (SB) 367- 934-28-110 Revision A, dated December 19, 2006. This SB introduces a “Safe- Life” Inspection and Test in the unit and therefore is equivalent to the requirements of TABLE 2. Therefore Embraer would like to suggest the inclusion of Parker SB 367-934-28- 110 Revision A, dated December 19, 2006 as an alternative method of compliance with the first inspection requirements as per TABLE 2 above. Embraer understands that ANAC AD 2007-08-02 also needs to be revised according to the comments presented herein. Best Regards, Sérgio Augusto Viana de Carvalho Certification Manager C.c.: Sanjay Ralhan (FAA) Oswaldo Oliveira Filho (ANAC) Edson Cury (ANAC)