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-024-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 Reference (A) proposed B747 AD would retain all of the requirements of Reference (B) but is adding, for certain 

airplanes, an inspection to determine material type of Main Entry Door (MED) reveals, repetitive inspections for 

cracking of 6061 machined aluminum one-piece corner reveals, and replacement with 6061 machined aluminum twopiece 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), an 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 COMMENTS

DAL believes that Para (r) and (s) actions and the required repetitive activities of the proposed Ref (A) are clear and 

understandable. However, when DAL reviewed 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 previously exist in prior revisions of the Service 

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 further 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