Comments in Response to FAA Final Rule; Request for Comments 

Docket No.: FAA-2016-3699 Directorate Identifier: 2015-NM-1 09-AD 

Comments have been received in response to: "Final rule; request for comments," 

Airworthiness Directive (AD) Docket FAA-2016-3699, Directorate Identifier 2015-NM-109-

AD. Please review these comments to determine if additional action is wan-anted. 

Once you have made your determination, please check the appropriate response, below. 

Include additional information following the appropriate response, if necessary. Then type in 

your name and date in the spaces provided, and this return this form to: 9-ANM-114-ADWorksheets. 

The FAA has reviewed comment(s) related to FAA AD Docket FAA-2016-3699, received from 

Boeing. 

_ ../_ These comments have not been found to contain any information to wanant 

reconsideration or revision of this AD. 

--- These comments have been found to contain information that warrants consideration of 

additional regulatory action. (SEE AD Manual FAA-IR-M-8040.JC, page 57, 

paragraph 6.a., FOR ADDITIONAL ACTION.) 

Comments # l and #2: 

Boeing requested that we change the wording of the AD to reference the entries inc01porated 

into the February 2015 revision of the Line Number Specific Airworthiness Limitations (AWLLNS) document, instead of referencing the document dated February 2015. Boeing also 

requested that we indicate that AMOCs per paragraph (h) are not necessary for future revisions of 

the document, if the revisions do not affect the applicable entries. 

Boeing stated that the A WL-LNS document will be updated periodically, and the cunent 

wording could trigger the need for an AMOC in the future, even if the entries applicable to the 

AD are unchanged. Boeing also stated that it is likely that when the inspections or tenninating 

actions prescribed by the A WL-LNS is accomplished, the revision date will have been changed, 

which could trigger the need for an AMOC. 

FAA Response: 

Paragraph (g) of this AD requires that the affected operators revise their maintenance or 

inspection program to incorporate the applicable inspection requirement specified in the AWLLNS document, within 30 days of the AD effective date. The A WL-LNS document dated 
February 2015 was still current at the end of the required compliance time (30 days after the AD 

effective date of March 9, 20 16). 

When the time comes to accomplish the inspections or terminating actions, the operators may use 

the A WL-LNS document dated February 2015, as required by this AD and already incorporated 

into their maintenance program. If they choose instead to use a later revision to the A WL-LNS 

document, they may request an AMOC at that time in accordance with paragraph (h) of the AD. 

It is not necessary to make the suggested change. However, we wi II make note of this suggestion 

for possible use in future ADs. 

Comment #3: 

Boeing requested that paragraph (g) indicate that tenninating action may be completed as 

prescribed in the A WL-LNS. 

FAA Response: 

Paragraph (g) of this AD requires that the affected operators revise their maintenance or 

inspection program to incorporate the applicable inspection requirement specified in the AWLLNS document. The terminating action is specified as part ofthe inspection requirement in the 

A WL-LNS document. Therefore, it is not necessary to repeat that information in the AD. 

Comment #4: 

Boeing requested to remove the word "other" from the statement under the FAA's Determination 

that "We are issuing this AD because we evaluated all the relevant information and determined 

that the unsafe condition described previously is likely to exist or develop in other products of 

the same type design." Boeing stated that the unsafe condition was limited to two specific line 

numbers, and is not li kely to develop in other products of the same type design, i.e., the entire 

787-8 fleet. 

FAA Response: 

This wording in this statement is taken directly from Title 14 ofthe Code ofFederal Regulations 

(14 CFR), §39.5, "When does FAA issue airworthiness directives?" Paragraph (c) ofthe AD 

states that the AD is applicable to Model 787-8 airplanes having two specific line numbers. 

Therefore, it is not necessary to make the suggested change. 

Comment #5 : 

Boeing suggested fixing the typographical error in paragraph (hX1 ), if making other revisions to 

the AD. 

FAA Response: 

We regret the typographical error, but will not be revising the AD to coiTect it. The Seattle 

Aircraft Certification Office is correctly identified in several other places in the AD, including 

paragraph (h)(3) and the email address listed in paragraph (h)(l). 

2 
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(This form is part of the official docket fi le for this AD action.) 

3 
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ECEIV .::f: 

rti---BDEING I\~ MAR 2 8 2016 l \_ _· - ~"' ' _ _ _ B'f•___, - J 

The Boe1ng Company 

PO Bcx 3707 

Sean e. WA98124-2207 

March24,20I6 ~ot./ . Ll} (cJ . 

B-H21 0-16-00161 

Docket Management Facility 

U.S. Department of Transportation 

400 Seventh Street SW 

Nassif Building, Room PL-401 

Washington, DC 20590 

Attention: Airwot'lhiness Rules Docket No. FAA-2016-3699 

r~ - H-D ~.o~ > 

Subject: Comments, IAR Docket No. F AA-2016-3699 (Directorate Identifier 

2015-NM-109-AD): Airworthiness Limitation for Repetitive 

Inspections of the Web Fastener Holes in the Overwing Flex-Tees, Airplane Model 787 

Boeing has reviewed the subj ect IAR and provides the enclosed comments. 

Very tntly yours, 

K. R. Guiley 

Manager, Continued Airworthiness 

Twin Aisle Programs 

B-H2 10, M/C OA-19, (425) 266-5697 

FAX: (425) 342-1058 

LAT 

Enclosure: Comment. , 3 pages 

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Boeing Proprietary 

Enclosure to B-H21 0-16-00161 

Page 1 of 3 

March 15, 2016 

787 Airframe-16-00 1 

Boeing Comments on IAR Docket No. F AA-20 16-3699 (Directorate Identifier 2015-NM-1 09-AD) 

Comment# ! 

What does the 

commente r request? 

How is the request 

j ustified? 

List paragraphs that 

change; describe 

(nonobvious) changes. 

I Revise wording that specifies the revision level of the Boeing 787 

j Airworthiness Limitations- Line Number Specilic, DO II 2009-03-02, dated 

Februmy 2015, 

'' .. . revise the maintenance or inspection program, as applicable, to 

incorporate the applicable inspection requirement identified in paragraphs I (g)( I ) and (g)(2) of this AD, as spec i ficd in applicable entries incorporated in 

the February 2015 revision of Boeing 787 Airworthiness Limitations-Line 

. Number Specific, DO II 2009-03-02, dated Februal)' 2015. The initial I compliance time for the tasks is at the applicable time specified in applicable 

. entries incorporated in the February 20 15 revision of Boeing 787 I Airworthiness Limitations-Line Number Specific, DO II 2009-03- 02, dated 

. Februal)' 20 15. 1 

I (I) For the airplane having line number 78: Principal Structural Element 57-

: I0-06a_MRB9, .. Overwing Flex-Tee- Web Fastener Holes.'' 

I (2) For the airplane having line number 82: Principal Structural Element 57-

I t 0-06a MRB I 0, · ·Overwing Flex-Tee-Web Fastener Holes."" 

The AD specifies the A WL-LNS document dated February 2015. The 

A WL-LNS is a document that will be periodically updated with new 

revisions unrelated to the entries specified in the AD. It is likely that when 

the inspections or terminating action prescribed by the A WL-LNS is 

accomplished, the revision date will have been changed, which could trigger 

the need for an AMOC (to the new revision, even though the entries 

applicable to the AD are unchanged). 

I 

I I (g) 

I 

Page 2 of4 

ECCN- 9E991 

NO LICENSE IS REQUI RED FORTH E DISSEM INATION OF THE COMMERCIAL INFO M-IA TlON CONTAINED HEREIN TO 

FOREIGN PERSONS OTB ER THAN THOSE FROM OR IN TERRORIST SUPPORTING COUNTRIES IDENT I Fl ED IN THE EAR. 

IT IS TBE RESPONSIBILITY OF THE INDIVIDUAL IN CONTROL OF THIS DATA TO ABIDE BY U.S. EXPORT LAWS. 
Boeing Proprietary 

Enclosure to 8 -H210-16-001 61 

Page 2 of 3 

March 15, 201 6 

787 Airframe- 16-001 

Boeing Comments on IAR Docket No. FAA-2016-3699 (Directorate Identifier 2015-NM-1 09-AO) [cont.] 

Comment #2 

What does the 

commenter request? 

How is the request 

j ustified? 

List paragraphs that 

change; describe 

(nonobvious) changes. 

Comment#3 

What does the 

commenter request? 

How is the request 

justified? 

List paragraphs rhar 

change; describe (nonobvious) changes. 

' Supplement wording to indicate "AMOCs per paragraph (h) are not required 1 for future revisions of787 Airworthiness Limitations- Line Number 

. Specific, DO II Z009-03-02, dated February 2015 if the revisions do not 

' affect content applicable to 57-1 0-06a MRB9 or 57- 1 0-06a MRB I 0." 

; The AD specifies the A WL-LNS document dated February 2015. The 

A WL-LNS is a document that will be periodically updated with new 

rev isions unrelated to the entries specified in the AD. lt is likely that when 

the inspections or terminating action prescribed by the A WL-LNS is 

accomplished, the revision date will have been changed, wh ich could trigger 

the need for an AMOC (for the new revision, even though the entries 

: applicable to the AD are unchanged). 

' 

: (g) 

I Supplement paragraph (g) with statements indicating tenninating action can I be completed as prescribed in the A WL-LNS (per Boeing Service Bulletin 

B787 8 1205-SB 5700 16-00-00 I) as an alternative to the applicable 

I inspection requ irement. Proposed wording is consistent with the applicable 

: notes in the A WL-LNS: 

I "The 57- l0-06a_MRB9 inspection is not required if airplane retrofit has I been accomplished in accordance with the tenn inating action defined in 

Boeing Service Bulletin B787 81205-SB 570016-00-001 prior to 16,000 

I flight cycles. 

I 

I 

: The 57-1 0-06a_MRB 10 inspection is not required if airplane retrofit has 

been accomplished in accordance with the te1minating action defined in 

Boeing Service Bulletin B787 81205-SB 570016-00-00 I prior to 7,000 flight 

• cycles." 

Potential retrofit terminating action for the AD prescribed in the A WL-LNS 

is not explicitly mentioned in the AD. 

I 

I 

: (g) 

' 

Page 3 of 4 

ECCN • 9E991 

NO LICENSE lS REQUIRED FOR THE DISSE.\UNATION O F THE COMMERCIAL INFORMATION CONTAINED HEREIN TO 

FOREIGN PERSONS OTHER THAN T HOSE FROM OR IN TERRORIST SUPPORTING COUNTRIES IDENTIFIED IN THE EAR. 

IT IS T HE RESPO!'iSIBILITY OF TH E INDIVIDUAL IN CONTROL OF THIS DATA TO ABIDE BY U.S. EXPORT LAWS. 
Boeing Proprietary 

Enclosure to B-H210-16-00161 

Page 3 of 3 

March 15,2016 

787 Airframe-16-00 I 

Boeing Comments on IAR Docket No. FAA-2016-3699 (Directorate Identifier 2015-NM-109-AD) [cont.] 

Comment#4 

What does the 

commenter request? 

How is the request 

justified? 

List paragraphs that 

change; describe (nonobvious) changes. 

Comment#5 

What does the 

commenter request? 

How is the request 

justified? 

List paragraphs that 

change: describe (nonobvious) changes. 

Revise wording to strike the word ''other .. from the following statement: 

"We are issuing this AD because we evaluated all the relevant information 

and determined the unsafe condition described previously is likely to exist or 

develop in etllef products of the same type design." 

The unsafe condition resulted from a quality escapement applicable to two 

specific line numbers, and therefore, is not likely to develop in OTHER 

products of the same type design (i.e. the entire 787-8 lleet). 

Docket wording in section titled "FAA's Detennination" 

I If making other revisions to the AD. fix the typographical error in the 

' 

following statement: 

"(h) Altemative Methods of Compliance (AMOCs) 

(I) The Manager, Seatt e~ Aircraft Certification Ortice (ACO), ... " 

clarity/correctness 

(h) 

Page 4 of4 

ECCN- 9E991 

NO LICENSE IS REQUIRED FOR Til£ DISSEMINATION OF THE COI\IMERCIAL INFORMATION CONTAINED HEREIN TO 

FOREIGN PERSONS OTIIER TIIAN THOSE FROM OR IN TERRORIST SUPPORTING COUNTRI ES IDENTIFIED IN THE EAR. 

IT IS THE RESPONSIBILITY OF THE INDIVIDUAL IN CONTROL OF TH IS DATA TO ABIDE BY U.S. EXPORT LAWS.