United Airlines (UA) concurs with the contents of the proposed rule and offers the following comments.
1. Paragraph (i) of the proposed AD requires prior or concurrent installation of an automatic shutoff system for the auxiliary fuel tank pump, in accordance with the Accomplishment Instructions of Boeing Service Bulletin 767-28A0083, Revision 2, dated February 12, 2009; or Boeing Service Bulletin 767-28A0084, Revision 1, dated April 26, 2007; as applicable. Accomplishing the requirements of AD 2009-16-06, amendment 39-15989, terminates the requirements of this paragraph. Service Bulletin 767-28A0083, Revision 2, dated February 12, 2009 is the applicable service bulletin to UA. During UA’s compliance with AD 2009-16-06, UA obtained FAA AMOC 140S-09-331, dated September 25, 2009, to install automatic shutoff system for the auxiliary fuel tank pump in accordance with Boeing Service Bulletin 767-28A0083, Revision 1, dated April 26, 2007. This AMOC is applicable to just three of UA’s thirty-five 767-300 airplanes because Service Bulletin 767-28A0083, Revision 1, dated April 26, 2007, was accomplished on the remaining thirty-two airplanes before the effective date of AD 2009-16-06. Therefore, UA suggests that the proposed AD include a paragraph to allow the AMOC issued to AD 2009-16-06 as approved for compliance with applicable paragraph of the proposed AD, in this case AD paragraph (i).
2. Paragraph (k) of the proposed AD requires concurrent revision of the maintenance program by incorporating Airworthiness Limitations (AWLs) No. 28-AWL-27 and No. 28-AWL-28 of Section 9 of the Boeing 767 Maintenance Planning Data (MPD) Document, D622T001-9, Revision April 2008; Revision March 2009; or Revision May 2009. Subsequent to MPD Revision May 2009, Boeing has since issued revisions to the MPD. The current MPD revision is Revision May 2010. Therefore, UA suggests that paragraph (k) of the proposed AD be revised to add reference to MPD Revision May 2010.
United Airlines
This is comment on Rule
Airworthiness Directives: Boeing Co. Model 767 Airplanes
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