In paragraph (e)(2)(ii) in the "Compliance" section in the proposed AD, it is
instructed that
====Quote====
(ii) For engines that do not have an ESV before the front turbine hub accumulates
9,370 CSN, remove the front turbine hub from service at the next ESV, or before
the hub accumulates an additional 6,000 cycles-since-last high pressure turbine
overhaul, whichever occurs first, but not to exceed 12,000 CSN.
====Unquote====
Japan Airlines (JAL) thinks that the terms "last high pressure turbine overhaul" in
paragraph (e)(2)(ii) in the "Compliance" section should be clearly defined to
comply with this proposed AD properly.
JAL believes that "last FPI of the front turbine hub, P/N 53L601" satisfies the
FAA's intention for this item, therefore, JAL would like to request FAA to change
the terms from "last high pressure turbine overhaul" to "last FPI of the front turbine
hub, P/N 53L601" in paragraph (e)(2)(ii) in the "Compliance" section.
Japan Airlines
This is comment on Rule
Airworthiness Directives; Pratt and Whitney PW4090 and PW4090-3 Turbofan Engines
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