United Parcel Service

United Parcel Service (UPS) would like to submit the following comments in response to the subject Notice of Proposed Rulemaking (NPRM), which proposes repetitive HFEC inspections of the underwing longeron fitting for cracking, and related investigative and correction actions if necessary, for all 767-200/-300/-300F/-400ER airplanes. UPS would like to point out the following errors in Boeing Alert Service Bulletin (SB) 767-57A0126, dated August 12, 2011, and Revision 1, dated November 9, 2011. - In Section B-B of Figures 7 through 10, the callout for Shim “D” refers to Step 16 instead of Step 12. - In Section B-B of Figures 7 through 10, the callout to cap seal the fasteners refers to Step 18 instead of Step 14. - In Steps 1, 4, and 8 of Figure 7 and 8, Shim C should be identified as BACS40R014C022F instead of BACS40R020C032F. - In Section B-B of Figure 7, the fastener through Radius Filler F is incorrectly called out as Bolt “A”, P/N BACB30NX8K19X and P/N BACB30NX8K20X. This fastener should be Bolt “B”, P/N BACB30NX10K19X and P/N BACB30NX10K20X. Boeing has notified UPS that the above changes will be incorporated in Revision 2 of SB 767-57A0126. If the proposed AD does not incorporate SB 767-57A0126 Revision 2 (and, by result, the incorporated changes), UPS requests that the AD language include the corrections identified above. UPS would also like to comment on the Costs of Compliance as presented in the proposed AD. In the table of on-condition costs, the NPRM identifies the parts cost range up to $11,551. However, according to Boeing Alert Service Bulletin (SB) 767-57A0126, dated August 12, 2011, paragraph 2.A, the parts kits that are required to accomplish the modification include one top kit for each wing. This results in parts cost ranging up to $12,058 for Group 1 aircraft and $14,290 for Group 2 aircraft. We appreciate your consideration of our comments.