United Airlines

United Airlines comments on 777 Elevator Attach Fitting NPRM Docket No. FAA-2012-0803; Directorate Identifier 2011-NM-214-AD. Following accomplishment of SB 777-55-0016 Rev 0 using the higher torque values on a United 777 aircraft, United removed both elevators and inspected the fasteners per the Boeing procedures. Damage was found on the RH elevator and United elected to replace the existing elevator (-2B) with a new production elevator (-18B) which had the post-SB configuration with the new actuator fittings installed from production using the correct torque values for the fasteners. As presently written the NPRM Paragraph (K) does not give credit for installation of a new elevator which has complied with the requirements of SB 777-55-0016 Rev 0 along with the correct torque values per SB 777-55-0016 Rev 1. United requests, that the NPRM be revised to include terminating action credit for installation of a new elevator which complies with all requirements of SB 777-55-0016 Rev 0 Mod including the correct torque values per SB 777-55-0016 Rev 1.