Atlas Air

Atlas Air comment to NPRM 2011-NM-067-AD, paragraph (h)(2). Atlas Air operates B767-200 airplane model variable numbers VA803, VA807, VA808, VA809 and VB302 which are all Group 1 airplanes. Airworthiness Directive (AD) 2002-19-11 paragraph (a), Amendment 39-12891 was complied with by the previous operator of datum airplane, ABX Air Inc. using Service Bulletin 767-78A0089, Revision 3, dated 18-Dec-2003. Service Bulletin 767-78A0089, Revision 5, dated June 09, 2009 was sent by Boeing to add the 315T3221-1 bushing installation for airplanes delivered with the 315T3222-3 bushing. Service Bulletin 767-78A0089, Revision 4 added the missing configuration for 315T322-3 bushing replacement in the aft cascade ring. However, Boeing received a report from an operator that the 315T3222-3 bushing could not be replaced by the 315T3222-10 bushing due to inadequate edge margin. Therefore, Revision Service Bulletin 767-78A0089, Revision 5 was issued to replace the 315T3222-3 bushing with a new 315T3221-1 bushing that will provide adequate edge margin. Accordingly, airplanes that are delivered with 315T3222-3 bushing configuration were moved to a new Group 2. Since Atlas Air airplanes are Group 1 and the requirement of AD 2002-19-11 was accomplished within the compliance times as shown in Revision 3 of Service Bulletin 767-78A0089, no more work is necessary. Therefore, Atlas Air recommends adding the following to paragraph (h)(2): For Group 1 airplanes, actions accomplished before the effective date of this AD in accordance with Boeing Alert Service Bulletin 767-78A0089, Revision 3, dated December 18, 2003 are considered acceptable for compliance with the corresponding requirements of paragraph (h)(2) of this AD.