All Nippon Airways

ANA submits the following comment and PDF. Comment to "Docket No. FAA-2010-0277; Directorate Identifier 2009-NM-217-AD'' 1. ANA’ Experience ANA has experienced a crack of RH Wing Upper Skin Panel at Front Spar Pitch Load Fitting Attachment on JA8273(VK087) on 24 Jul 2004 (FC/FH: 36228/32848) during Boeing SB 767-54-0081 R1. Refer to Boeing SR ID: 1-34849078, 1-35504206. 2. ANA’ Applicability ANA had completed SB 767-54-0081 R1 for all our fleet. Our 767-300 airplanes are applicable to Group 5, Configuration 2 (38 airplanes) and Group 6 (20 airplanes) as defined SB 767-57A0117. 3. Compliance ANA has escalated C check maintenance interval from 3,000FC (MPD) to 3,750FC, therefore, we request FAA to keep initial inspection threshold “Within 4,000 FC or 12,000 FH after the date on this Service Bulletin (whichever occurs first)” as defined SB 767-57A0117 Org, paragraph 1.E. Table 9 & 10. 4. Paragraph (i) Clarification Exceptions to the Service Bulletin, Paragraph (i) in NPRM No.2009-NM-217-AD shows that “If any cracking is found during any inspection required by this AD, and Boeing Alert Service Bulletin 767-57A0117, dated October 1, 2009, specifies to contact Boeing for appropriate action: Before further flight, repair the cracking using a method approved in accordance with the procedures specified in paragraph (k) of this AD”. ANA supposes that “specifies to contact Boeing for appropriate action” is not clear. SB 767-57A0117 has repair procedures in paragraph 1.E. Condition 2 (2A thru 2D) at each tables. Condition 2D only requires to contact Boeing for additional instructions and do the repair before further flight. ANA understands that paragraph (i) in NPRM No.2009-NM-217-AD is only applicable the “Condition 2D” in SB 767-57A0117, paragraph 1.E. Tables. Therefore, ANA requests FAA to add “Condition 2D” in SB 767-57A0117, paragraph 1.E. Tables to paragraph (i) in NPRM No.2009-NM-217-AD.