KLM Fleet Services

Paragraphs (f) and (g) states: (f) For all airplanes: Within 60 months after the effective date of this AD, measure the electrical bond resistance between the MOV actuators and airplane structure for the main, center, and auxiliary fuel tanks as applicable, and do all the applicable corrective actions, by accomplishing all of the applicable actions specified in the Accomplishment Instructions of Boeing Alert Service Bulletin 747- 28A2292, dated September 14, 2007. The corrective actions must be accomplished before further flight. (g) For Model 747-400 series airplanes identified in paragraph 1.A of Boeing Alert Service Bulletin 747-28A2294, dated September 21, 2007: Within 60 months after the effective date of this AD, measure the electrical bond resistance between the MOV actuators and airplane structure for the horizontal stabilizer fuel tanks, and do all the applicable corrective actions, by accomplishing all of the applicable actions specified in the Accomplishment Instructions of the service bulletin. The corrective actions must be accomplished before further flight. KLM COMMENT: For the corrective actions specified in Boeing Alert Service Bulletin 747-28A2292, dated September 14, 2007 and in Boeing Alert Service Bulletin 747-28A2294, dated September 21, 2007 a tank entry might be required. KLM wants to avoid tank entries during C-checks, therefore, KLM requests the FAA to extend the deadline of paragraphs (f) and (g) to 8 years after effective date of the forthcoming AD (KLM 747-400 aircraft have a D-check interval of 6 thru 8 years). Paragraphs (h) and (i) states: (h) For Model 747-100, 747-100B, 747-100B SUD, 747-200B, 747-200C, 747- 200F, 747-300, 747SR, and 747SP series airplanes: Concurrently with accomplishing the actions required by paragraph (f) of this AD, revise the FAAapproved maintenance program by incorporating AWL No. 28-AWL-21 of Section D of the Boeing 747-100/200/300/SP Airworthiness Limitations (AWLs) and Certification Maintenance Requirements (CMRs), D6-13747-CMR, Revision January 2007. Accomplishing the revision in accordance with a later revision of Document D6-13747-CMR is an acceptable method of compliance if the revision is approved by the Manager, Seattle Aircraft Certification Office (ACO), FAA. (i) For Model 747-400, 747-400D, and 747-400F series airplanes: Concurrently with accomplishing the applicable actions required by paragraph (f) and (g) of this AD, revise the FAA-approved maintenance program by incorporating AWL No. 28-AWL-27 of Subsection D of the Boeing 747-400 Maintenance Planning Data (MPD) Document, D621U400-9, Section 9, Revision December 2006 R1. Accomplishing the revision in accordance with a later revision of the MPD is an acceptable method of compliance if the revision is approved by the Manager, Seattle ACO, FAA. KLM COMMENT: The intention of paragraphs (h) and (i) is to maintain the design features introduced per Boeing Alert Service Bulletin 747-28A2292, dated September 14, 2007 and in Boeing Alert Service Bulletin 747-28A2294, dated September 21, 2007 as applicable when a Motor Operated Valve (MOV) Actuator is installed. KLM thinks that it is more clear when these paragraphs state that CDCCL's into the applicable paragraphs of the Aircraft Maintenance Manuals (AMM) must be incorporated (action Boeing).