Southwest Airlines

Comment #1: NPRM Requirement: Paragraph (i), Note 1 of the NPRM states, “Guidance on repairs can be found in Boeing 737-100/-200 53-30-1, Figure 20, 21, 31, or 32; or Boeing 737-300/-400/-500 SRM 53-10-01, Repair 5, 6, or 8; as applicable.” SWA Questions/Comments: SWA has aircraft affected by this NPRM in the 737-300 and -500 fleets. SWA notes that Boeing 737-300/-500 SRM 53-10-01, Repair 5, 6, and 8 have been removed as they are no longer applicable. Therefore, SWA believes the NPRM is in error when it states that guidance on repairs can be found in these locations. SWA Proposed Solutions: Delete Note 1 in paragraph (i) from the NPRM/AD. Comment #2: NPRM Requirement: Paragraph (j) of the NPRM states, “If any crack is found, before further flight, repair using a method approved in accordance with the procedures specified in paragraph (o) of this AD.” SWA Questions/Comments: SWA has aircraft affected by this NPRM in the 737-300 and 737-500 fleets. SWA notes that Boeing 737-300/-500 SRM 53-10-01-2R-14 provides a repair for the Forward Entry Door, Upper and Lower Hinge Cutout locations. SWA notes that Boeing 737-300/-500 SRM 53-10-01-2R-15 provides a repair for the Forward Galley Door, Lower Hinge Cutout location. Neither repair is identified in the NPRM as an acceptable means to address cracks found during inspections required per paragraph (j). SWA Proposed Solutions: Provide language in paragraph (j) or a subsequent paragraph that states performing a repair in accordance with Boeing 737-300/-500 SRM 53-10-01-2R-14 or 53-10-01-2R-15 is considered terminating action of paragraph (j) requirements for the repaired location.