Subject: Request to Delay Implementation of Notice of Proposed Rulemaking

(NPRM) 2002-NM-12-AD

~

BOEING

The Boeing Company

P.O. Box 3707

Seanle. WA 98124.2207

NOV 07 2002

B-H21O-02-0509

Transport Airplane Directorate, ANM-103

Airworthiness Rules Docket No. 2002-NM-12-AD

Federal Aviation Administration

Northwest Mountain Region

160 I Lind Avenue Southwest

Renton, Washington 98055-4056

Dear Ms. Opland:

RECEIVED

NOV I ~ 2002

ANM -114

References: (a) NPRM 2002-NM-12-AD

(b) Boeing Letter B-H360-02-4343, Comments Related to the Static

Inverter NPRM No. 2002-NM-12-AD, dated June 28, 2002

Please forward a copy of this correspondence to Mr. B.V. Tran (FAA Specialist,

ANM-130S).

Boeing respectfully requests a delay of the reference a) NPRM until November 15,

2002. Comments to this NPRM have been previously provided to the FAA by reference

(b) The delay in releasing the NPRM will ensure that the latest revision of Avionics

Instruments, Inc. Service Bulletin 1-002-01-2-1000-24-24 is available.

If you have any questions, please contact this office or Dennis Anderson at

(425) 717-2401.

The information being forwarded to the FAA, by or with this correspondence, is

considered proprietary to The Boeing Company, and is provided on a confidential

basis.

Very truly yours,

'3 t. c., tCct.N-l v-lt.;)

B. C. Groenewegen

Manager, Continued Airworthiness

Twin Aisle Programs

B-H210, M/C 02-85, (425) 717-2399

FAX: (425) 266-2699

DLA
JUN 2 8 2002

B-H360-02-4343

;UL-11-2002

_. -

08: 19 FAA SEATTLE ACO

The Boeing Company

P,O. Sox 3707

Seattle, WA 98124-2207

RECEIVED

425 227 1182 P.02

~ &rfd-I

ROUTE

Dear Ms. Liu-Nelson:

JUL 02 2002

ANM.100S ..

FM-SACO

Comments Related to the Static Inverter

NPRM No. 2002-NM-12-AD

Ms. Lirio Liu-Nelson

Manager, ANM-IOOS

Department of Transportation

Federal Aviation Administration

Seattle Aircraft Certification Office

160 I Lind Avenue SW

Renton, WA 98055-4056

Subject:

Reference: Electrical Power-Static Inverter-Bridge Assembly RI70

Relocation Service Bulletin from Avionic Instruments Inc.,

Number 1-002-0102-1000-24-24, dated July 19, 1999

This letter provides our formal comments related to the pending AD associated ",ith

the subject NPRM NO.2002-NM-12-AD.

Avionic Instruments, Inc. (AI') estimates that approximately 3,200 static inverters

mil require implementation of Service Bulletin 1-002-0102-1000-24-24. AI' can

process approximately 100 units per month. Therefore, a 42-month compliance time

period is requested.

Under "Explanation of Relevant Service Information". the NPRM reads as follows:

"The FAA has reviewed and approved Boeing Service Letters 737 -Slr24-165,

747-5L-24-058 ..." etc. The FAA typically does not, if ever, approve a Boeing

Service Letter, and Boeing has not been able to locate any such approval. However,

Boeing does have record of FAA approval of the Avionic Instruments Service

Bulletin, 1-002-0102-1000-24-24, which is referenced in the Boeing Service Letters.

In the "APPLICABILITY" table, the Model 737-700C is missing, although it is

included in the listing under "SUMMARY".

The formatting of the "APPLICABILITY" table could be misleading. The dotted

lines in the table could cause the misinterpretation that only the Boeing -5 inverter is

used on the 737, only the Boeing -7 inverter is used on the 747, etc.

Under "Spare Parts", the NPRJ,,! reads as follows: "(b) As of the effective date of

this AD, no person may install. on any airplane, a static inverter having a part

number listed in the applicability section of this AD, unless the static inverter has

been modified in accordance with the requirements of this AD". This seems to

contradict the requirement, under "Modification", that static inverters be modified

within 18 months of the effcctive date of the AD. Boeing therefore strongly

recommends that the requirement under "Spare Parts" be relaxed to allow operators

a rcasonable length of time, after the effective date of the AD, to modify their spares.

Operators mil require a substantial period of time following the effective date of the

AD to implement plans to cycle unmodified static inverters off their airplanes, into a
JUL-11-2002 08:19 FRR SERTTLE RCO 425 227 1182 P.03

,..

DDE'NC

Page 2

Ms. Lirio Liu-Nelson

B-H360-02-4343

modification facility, and back into their fleet. Until this cycle of remove, modify,

and return-to-service is complete, it is likely that at anyone time the only spare static

inverter(s) available to support fleet operations will be unmodified static inverter(s).

Please contact this office or Keith Cebell at (425) 342-3843 if you have any

questions.

The information being forwarded to the FAA by or with this correspondence is for

the exclusive purpose of support of applications for or amendments to Type

Certificates, is considered proprietary to The Boeing Company, and is provided on a

confidential basis.

The data provided should be returned to Boeing immediately following use by the

FAA, including any copies thereof which the FAA may be required to make in the

course of its review. Boeing does not authorize the FAA to retain any portion of the

materials being supplied.

Very trulv yours,

. Blankinshi p

anager, Airplane Certification

Twin Aisle Deliveries & Fleet Support, B-H360

~ail Code 02- 79

Phone (425) 342-3810, FAX (425) 342-7546

KNC

TOTRL P.03
Tho Boeing Company

P.O. Box 3707

Seattle, WA 98124.2207

JUN 202006

B-1I21O-06-0392

Docket Management Facility

u.s. Department of Transportation

400 Seventh Street SW

Nassif Building, Room PL-40 I

Washington, DC 20590

Attention: DOT Rulemaking Docket No. 2002-NM-l2-AD 0-

BOEING

Subject: Comments on Supplemental NPRM Docket No. 2002-NM-12-

AD: "Modification of Static Inverter By Relocation of Resistor

RI70 of the Ststic Inverter Bridge Assembly", Airplane Model

737,747-400,757,767, and 777

Boeing bas reviewed the subject NPRM and provides the enclosed comments.

Very truly yours,

"B.t. G~~

B. C. Groenewegen J

Manager, Continued Airworthiness

Twin Aisle Prognuns

H-H2l0, M/C OA-87, (425) 266-4030

FAX: (425)342-5219

dla

Enclosure; NPRM Comments 1 page
Comment #

v,'hat does the

commenter re ucst?

How is the rcqut:st

justified?

List paragraphs thai

change: describe

(nollobvious)

chan 'es.

Enclosure to B-H21 0-06-0392

Page I of I

Comments on NPRM Docket "'0. 2002-NM-12-AD

Address imminent revisions to two of the service bulletins identified in the

co ased AD. as well as ossiblc future revisions to an of the identified bulletins.

Revisions are inuninent to the 747 and 777 bulletins which will add se ••.eral

airplanes to the Effectivity lists in the bulletins. As written, the "Applicability"

am fa h in the co sed AD will not include the added a" lanes.

"Applicability ,. paragraph and paragraph (a) under "Modification": Suggest

changing to read .•... the applicable service bulletin specified in Table 1 of this AD

or ~'ubsequent revls/on(s) 10 that bulletin.

Comment # 2

""hat does the Remove 747 and 777 from the applicability ofthc proposed AD.

commcnter reQuest?

How is the request Boeing Safety Review Board made a finding of "Not Safety" for the 747 and 777.

justified? There havc bcen no failures on these models, and the inverters on thcse models arc

not runnim! durin!! nonnal operations.

List paragraphs that "Table J .-Applicability"

l:hange: describe

(nonohvious)

ehanees.

6/19/2006

4:33:53 PM
~

BOEING

The Boeing Company

P,O. Box 3707

Seattle, WA 98124.2207

June 19.2006

B-H2IO-06-0390

Docket Management Facility

U.S. Department of Transportation

400 Seventh Street SW

Nassif Building, Room PL-401

Washington, DC 20590

Attention: Airworthiness Rules Docket No. 2002-NM-12-AD

RECEIVED

JUN 27 2006

ANM-114

•

Subject: Comments, SNPRM Docket No. 2002-NM-12-AD:

"Modification of Static Inverter by Relocation of Resistor

R 170 of the Static Inverter Bridge Assembly", Airplane

Models 737-300/400/500, and 757

Boeing has reviewed the subject NPRM and concurs with the contents of the

proposed rule. Therefore, no additional comments will be forthcoming.

Very truly yours,

. K. Dial

Manager, Continued Airworthiness

Single Aisle Programs

B-H2IO, MC 67-TC, (425) 237-9472

FAX: (425) 234-4649

Jam