Japan Airlines

Document ID: FAA-2011-0278-0002
Document Type: Public Submission
Agency: Federal Aviation Administration
Received Date: May 31 2011, at 12:00 AM Eastern Daylight Time
Date Posted: June 2 2011, at 12:00 AM Eastern Standard Time
Comment Start Date: May 26 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: July 11 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80e351fe
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This is comment on Rule

Airworthiness Directives: General Electric Co. GE90-110B1 and GE90 115B Turbofan Engines

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Docket No. FAA-2011-0278; Directorate Identifier 2010-NE-10-AD Q1. 'Installation Prohibition' portion of this NPRM prohibits us from installing any HPC forward case unless it has an HPC stator stage 1 interstage seals, P/N 351-109-503-0. Meanwhile, GE90-100 S/B 72-0360 states that we can install either worn seals P/N 351-109-502-0(pre-GE90-100 S/B 72-0358) or 351-109-503-0(post-GE90-100 S/B 72-0358). 'SUMMARY' portion of this NPRM also states that non-pregrooved seals should not be installed to prevent heavy rub, so we are confident that worn/used seals P/N 351-109-502-0 can be installed. Therefore, please allow us to install worn/used P/N 351-109-502-0 seals. Q2. Paragraph 3.B. of GE90-100 S/B 72-0320 Revision 2 clearly states that use of alternate ECI instrument is permitted under certain conditions, and we use alternate instrument, Nortec 2000S, after obtaining GE's approval. We do not deviate from the instruction of the SB, and we are confident that AMOC is not required for using alternate ECI instrument, but please advise your comment.