All Nippon Airways

ANA has experienced total sixty-five (65) cracks in the inner chords at both left-side and right-side stations 859.5, 883.5, and 903.5, prior to release of SB 767-53A0209 Rev 1 dated 24-July-2011. In many cases, we contacted Boeing to obtain repair procedures and also we got FAA 8100-9 Form as a repair approval and an AMOC to AD 2003-18-10. SB 767-53A0209 Rev 1 and this proposed AD do not describe how operators treat the previous FAA approved repairs prior to the release of the SB. If new AD does not include the treatment of the previous FAA approved repairs, we have to obtain FAA approvals for the all previous FAA approved repairs as an AMOC to new AD. This is big burden for ANA and also huge man hours/costs are required in ANA and Boeing for the message and paper work. On the other hand, SB 767-53-0207 mandated by AD 2011-02-06 describes that “Airplanes with FAA approved repairs for skin cracking at the subject location prior to the release of this service bulletin, do not require this service bulletin action.” This sentence is very useful for operators which had accomplished the FAA approved repairs prior to the release of the SB. Therefore, we request FAA to include the below intention into new AD requirement. “The inspection of the locations where FAA approved repairs have been accomplished for the inner chord cracking at both left-side and right-side stations 859.5, 883.5, and/or 903.5 prior to the release of SB 767-53A0209 Rev 1, are not required by this new AD.”