Japan Airlines

Reference: /A/ Docket No. FAA-2011-0025; Directorate Identifier, (2010-NM-208-AD) /B/ Boeing MPD, D622W00-9, Subsection B, of Section 9, Jan 2010 revision Japan Airlines has reviewed the proposed rule and provides the following comments regarding ref /A/: Comment 1, Proposed AD requested to revise the maintenance program by incorporating the information in Subsection B, Airworthiness Limitation-Structural Inspections, of Section 9, of “Airworthiness Limitations(AWLs) and Certification Maintenance Requirements(CMRs),”D622W001-9, Revision January 2010, of Boeing 777 Maintenance Planning Data(MPD) Document. However, the latest revision of “D622W001-9” is Revision August 2010. Therefore, AD should call out the latest revision or both revision January and August 2010. Comment 2 D622W001-9 requested the reporting of defect to FAA and Boeing within 10 days. However it is unclear from defect fond or other timing. We request to clarify the reporting requirement within 10 days from return to service of the airplane because of the following reason, The inspections usually conduct within Heavy Maintenance Visit which is usually elapsed over 10 days. Reporting of inspection results will be submitted after the term of Heavy Maintenance Visit. Therefore, it is very difficult to submit report to FAA or Boeing within 10 days from defect found. Comment 3 Repeat inspection procedures and intervals should be determined by DTR Check Form. Boeing usually incorporates recommended repeat inspection procedures and intervals in MPD Section 2, Structural Inspection Program. However, the latest MPD Section 2 includes the data of 777-200 series only and no data of 777-200LR, 300, 300ER and 300F. Therefore, AD should exclude incorporation of the repetitive inspection requirements for 777-200LR, 300, 300ER and 300F airplanes until MPD include the data for these airplanes. Best regards,