Subject: FedEx Comments for Docket No. FAA-2010-0228; Directorate Identifier 2009-NM-252-AD
The following comments/recommendations related to NPRM 2009-NM-252-AD
are submitted for your consideration:
FedEx concurs with the AD requirements and should be able to comply with requirements within the compliance time. In NPRM 2009-NM-252-AD, under Action (g), it states to perform a general visual inspection in accordance with Boeing alert Service Bulletin MD11-28A124, dated June 17, 2009. However, Boeing issued Service Bulletin Information Notice 01 (IN 01), dated October 01, 2009 that corrects Boeing alert Service Bulletin MD11-28A124; therefore, Information Notice 01 has to be referenced on AD.
Also, under Approval Status of IN 01 is states “The information contained in this Information Notice is NOT approved by the Federal Aviation Administration (FAA) or any other regulatory authority. This Information Notice is not intended to be used as the basis for deviation from the approved Service Bulletin”
As you can see, this IN 01 and the way the AD is worded under compliance will prevent FedEx to comply with this AD unless an AMOC is granted by the FAA. To correct this problem, please re-word, under the action required, to read “(g) within 60 months after the effective date of this AD, perform a general visual inspection to detect damage of wire assemblies of the tail tank fuel system, in accordance with the Accomplishment Instructions of Boeing Alert Service Bulletin MD11-28A124, dated June17, 2009, and MD11-28 A124 IN 01, dated October 01, 2009.
Screw P/N NAS1096-3-12 callout in drawing SR11280052 is not included in kit P/N SA11280124; therefore, SB MD11-28A124 will have to be revised to include P/N NAS1096-3-12. Please coordinate with Boeing before the new AD is issued.
Best regards,
Tito Ledezma
FedEx
Aircraft Systems Engineering
901-224-4648
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FedEx Public SubmissionPosted: 04/21/2010
ID: FAA-2010-0228-0004
FedEx
This is comment on Rule
Airworthiness Directives: McDonnell Douglas Corporation Model MD-11 and MD 11F Airplanes
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Public Submission Posted: 04/21/2010 ID: FAA-2010-0228-0004
Apr 30,2010 11:59 PM ET