KLM Royal Dutch Airlines

KLM comments to docket number FAA-2009- 0686; Directorate Identifier 2009-NM-044-AD KLM generally agrees with the intent of NPRM 2009-NM-044-AD, however KLM has the following comments on the proposed compliance period: In the Boeing Service Bulletin SB MD11-28-126 it is stated “This service bulletin assumes that the area above the center upper auxiliary fuel tank is open and access is available to all the floor beams for maintenance”. This area is for KLM only open during D-check (72 months interval). In this condition the estimated work hours according to NPRM is 136 to 154 hours depending on airplane configuration. KLM considers the work hours (and therefore operator costs) as specified in NPRM 2009-NM-044-AD (136 and 154 work hours depending on airplane configuration) as unrealistic, because KLM will not be able to perform the Boeing Service Bulletin SBMD11-28-126 during D-check (72 months period). Therefore if this area above the center upper auxiliary fuel tank is closed and access is not available to all the floor beams for maintenance, the following items during C-check at least will have to be removed from the aircraft to gain access to inspection area: 1. Eight seat rows, several floor panels and carpets 2. two toilets 3. and a Class divider Further because the inspection area is under the lavatory and also at a door area, there is a greater concern for structural corrosion findings under the floor panels. If during inspection there are corrosion findings this will extend the ground time for at least additional 6 days. KLM considers the 60 months compliance period for the inspection as undesirable, because the operator impact is not taken into consideration for operators as KLM, that have the area above the center upper auxiliary fuel tank only opened during 72 month period. Based on the arguments above and KLM not having any experience with wiring problems in this area, KLM kindly requests the FAA to review the compliance time and consider an extension to fit in the KLM D-check interval of 72 months (6 years). The expected additional hours and cycles for this additional period will be ± 4700 flight hours and 690 fight cycles.