Comment from Lufthansa Technik AG
Lufthansa Technik AGSupportBusiness
Summary: Lufthansa Technik AG requests that the FAA expand the scope of the proposed Airworthiness Directive to include repaired Main Fuel Pumps (MFPs) that have undergone specific screw replacements. They argue that because these repairs are traceable via specific Service Bulletins, repaired units should be considered eligible for installation alongside new and overhauled units.
Dear FAA-team,
in 2. (g) (2) the NPRM defines which Main Fuel Pumps (MFPs) are considered eligible in the sense of the proposed AD.
In addition to new units, this includes overhauled units that have undergone replacement of the screws in accordance with SB GEnx-1B SB73–0117 or GEnx-2B SB73–0110.
Lufthansa Technik would like to point out that these Service Bulletins do not require an overhaul of the MFPs. They refer to component Service Bulletin 82933-73-0006, in which the replacement of the screws is recommended independently of the accomplished workscope.
As a consequence, also repaired units should fulfill the requirements of the AD, provided that the screw replacement has been performed in accordance with the applicable Service Bulletins.
Compliance with the Service Bulletins is clearly traceable by the marking on the SB plate (to be marked with SB “73-0006” as described in SB 82933-73-0006).
Lufthansa Technik therefore requests to include REPAIRED MFPs, which have been modified in accordance with SB GEnx-1B SB73–0117 or GEnx-2B SB73–0110 and the associated component SB 82933-73-0006, as eligible parts under the AD (to be added with 2. (g) (2) (v)).
In fact all MFPs marked with SB 73-0006 on the SB plate shall be eligible for installation.
Thanks and best regards,
Michael Deichen
Component and Production Engineer
Engine Fuel Components
Lufthansa Technik AG