Craig Amadeo General Manager Engineering Standards & Chief Engineer Delta Air Lines, Inc.

1775 MH Jackson Service Road
Atlanta, GA, 30354

T. +1 404 714 1312

F. +1 404 773 3675 craig.amadeo @delta.com

June 25 , 2013

U.S. Department of Transportation Docket Operations, M

- 30, West Building Ground Floor, Room W12

- 140 1200 New Jersey Avenue SE Washington, DC 20590 Fax: (202) 493

- 2251

Subject : Docket No. FAA

- 2013

- 0366 ; Directorate Identifier 2011

- NM

- 0 24

- AD : Material Type Inspection of Main Entry Door Reveal

– Proposed Rule

Reference: (A) Notice of Proposed Rule Making (NPRM): Docket No. FAA

- 2013

- 0366 ; Directorate

Identifier 2011

- NM

- 024

- AD (B) Airworthiness Directive (AD) 2008

- 18

- 07 : Inspections of Main Entry Door Reveals (C) Boeing Service Bulletin 747

- 53

- 2460 Rev 2, dated 22Dec2010 (D) Boeing Message Number DAL

- DAL

- 13

- 1299

- 02B, dated 24Jun13 ( E ) Boeing Information Notice, 747

- 53

- 2460 IN 03 , dated 24Mar11

SUMMARY :

The R efe rence (A) proposed B747 AD would retain all of the require ments of Reference (B) but is adding, for certain airplanes, an inspection to determine material type of Main Entry Door (MED) r eveals, repetitive inspections for cracking of 6061 machined aluminum one

- piece corner reveals, and replacement with 6061 machined aluminum two

piece corner reveals if necessary. The proposed AD would also allow two

- piece corner reveal replacement as an option for certain inspections. Since the issuance of Reference (B), a n operator reported a crack in 6061 machined aluminum

one

- piece corner reveal and therefore further inspections are necessary on airplanes having these one

- piece reveals.

DELTA’S COMMENT S

D AL believes that Para (r) and (s) actions and the required repe titive activities of the proposed Ref (A) are clea r and

understandable. However, w hen DAL review ed the associated Table 1 conditions with the actions and required repetitive activities in the associated Service Bulletin (Reference (C)) for alignment with Para (r) and (s), DAL was not able to clearly determine which conditions are linked to each other. As confirmed by Ref (D), Boeing understands that the compliance table(s) of Ref (C) requires clarification for operators use and DAL urges the FAA to ensure to support an expedited revision to Ref (C) prior to AD issuance

.

In addition, DAL observed in the last row under the “Action” column of Ref (C) Table 8, there is a reference to “Table

9

. ” However, Table 9 is not present in Ref (C) nor did Table 9 pr eviously exist in prior revisions of the Servi ce Bulletin. DAL believes this “Table 9” reference should be “Paragraph 3.B., Part 2” as confirmed by Boeing in a related operator message issued on 15May13. Moreover, DAL has discovered that Ref ( E ) outlines several changes to certain Ref (C) FlagNotes . It is likely that all operators will be reviewing/ utilizing Table 8 and the noted flagnotes for AD incorporation into their programs, and therefore DAL urges the FAA to support an expedited revision to Ref ( C) prior to

AD issuance , address the error in the pending AD, or, at minimum, address these issues via global AMOC

.June 25, 2013 Page 2 of 2

If you have any f urther questions or require additional information

, please contact Sandy Coplien

– Principal Engineer

, Department 579 , at (404) 677

- 1762 or via email at sandra.coplien @delta.com

.

Thank you

,

Peter J. Lauria ODA Lead administrator and Acting Chief Engineer Dept. 574

– MSP

for Craig Amadeo General Manager

– Engineering Standards & Chief Engineer Dept. 567