All Nippon Airways

Document ID: FAA-2009-0607-0005
Document Type: Public Submission
Agency: Federal Aviation Administration
Received Date: August 20 2009, at 11:38 AM Eastern Daylight Time
Date Posted: August 20 2009, at 12:00 AM Eastern Standard Time
Comment Start Date: July 13 2009, at 12:00 AM Eastern Standard Time
Comment Due Date: August 27 2009, at 11:59 PM Eastern Standard Time
Tracking Number: 80a0d034
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This is comment on Rule

Airworthiness Directives: Boeing Model 747 100B SUD, 747 200B, 747 300, 747 400, and 747 400D Series Airplanes

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ANA Comments on NPRM 2009-NM-024-AD: Docket No. FAA-2009-0607. Ref. SB 747-53A2559 Org. ANA would like to comment followings for Docket No. FAA-2009-0607; Directorate Identifier 2009-NM-024-AD 1. On paragraph (m), modification and post modification inspection per SB 747-53A2559, dated January 8, 2009 is addressed. However, Boeing issued SB 747-53A2559 IN01, dated April 16, 2009 because the SB contains several typographical errors. To alleviate AMOC during the modification, ANA would like to request the FAA to review SB 747-53A2559 IN01 information and include required information into the final rule. 2. On paragraph (m), additional modification requirement is addressed. Based on discussion between ANA and Boeing, additional modification addressed in SB 747-53A2559 would be open hole HFEC inspection, not modification. We believe future revision of SB 747-53A2559 will clarify this requirement. However, to clarify the requirement prior to the future SB, ANA would like to request the FAA to revise the wording of "additional modification". 3. Based on our experience of the modification per DWG 144U0061, identical to SB 747-53A2559, required work hours exceeds 2,000 hours. Estimated costs are based on work hours addressed in SB 747-53A2559. We feel actual work hours should be considered to estimate costs. Best Regards, ANA Engineering Department Shinichi Yoshizaki