UPS

UPS would like to express concerns about the proposed NPRM 2010-NM-272-AD that requires operators to change the drain path along the leading edge of the 767 wing to prevent flammable fluids from draining inboard and onto the engine exhaust nozzle. As stated in Boeing’s service bulletin 767 57-0121 and in the NPRM, the reason for the modification was from one fuel leak on 737 that was traced back to a loose retaining nut on the slat track stop bolt. UPS believes this specific problem was addressed by AD 2011-03-15, Boeing S.B. 767-57-0118 R1, which checks all the slat track stop bolts and slat track housings for debris and corrects any discrepancies found. Since the slat track is designed similar to the 737, the specific condition of the loose slat track stop bolt that was reported on the 737 aircraft has already been addressed in AD 2011-03-15. There is also a concern that the modification will not address any or all fuel leaking along the leading edge of the wing for the 767 airplane. Although the slat track system between the 737 and the 767 share some similar design, the wing itself and fluid drain path is very different. SB 767-57-0121 was written to change the drain path but was based around a specific incident for the 737 wing. Therefore, the modification based on the single incident cannot ensure that all flammable fuel leaks on a 767 aircraft will be addressed in the modification. UPS supports any efforts made by the FAA and the manufacturer to ensure safety and respectfully request that the actions call out in AD 2011-03-15 be considered in place of the proposed actions specified in NPRM 2010-NM-272-AD.