Delta Air Lines

SUBJECT: Docket No. FAA-2012-1320, Directorate Identifier 2012-NM-095-AD RIN 2120-AA64; B767 MLG Pivot Joint. REFERENCES: /A/ Notice of Proposed Rule Making (NPRM) FAA-2012-1320, Directorate Identifier 2012-NM-095-AD /B/ Service Bulletin 767-32A0227, Rev 1, dated 9-13-2012. SUMMARY: Reference (A) proposed B767 AD would require incorporation of new lube task, repetitive inspections of the main landing gear (MLG) pivot joint, and bushing replacement for the MLG pivot joint. DELTA’S COMMENTS: Delta has reviewed the Ref (A) NPRM and the Ref (B) Service Bulletin, and we have the following 3 recommendations: 1. Update wording in paragraph (h) of the NPRM. Paragraph (h) of the NPRM refers to inspections of the “MLG pivots”. Delta believes that the paragraph should instead refer to “MLG pivot pins”. Please verify and update, for clarity. 2. Please add references regarding which “Part” of the S/B to be accomplished in Paragraphs (h) and (i). For example, paragraph (g) refers to accomplishing Part 1 of the S/B, therefore this paragraph is very clear. In contrast, paragraphs (h) and (i) do not refer to which “Part” in the S/B to be accomplished. Adding the reference to the “Part” to be accomplished would clarify the AD requirements. Paragraph (h) refers to doing A/C which are Group 1 only, refers to doing the detailed and etch inspections of the pivots, truck beam bushings and inner cylinder bushings, and includes instructions to repeat the inspections. Table 2 in the S/B defines doing Part 2 on Group 1 A/C, defines Pivot Pin and Bushing detailed inspections, and are repeated every 2,250 days, which appears to match paragraph (h) of the AD. Therefore Delta recommends that end of the first sentence in paragraph (h) should be revised to state “ … in accordance with Part 2 of the Accomplishment Instructions of Boeing Service Bulletin 767-32A0227” Paragraph (i) does not refer to a “group”, which would apply therefore to all A/C. The S/B