1400 North Hurstbourne Parkway 

Louisville, KY 40223 

502.329.3000 Tel 

June 23, 2014 

Federal Aviation Administration 

CIO U.S. Department ofTransportation 

Docket Operations, M-30 

West Building Ground Floor 

Room Wl2-140 

1200 New Jersey A venue SE 

Washington, DC 20590 

Subject: Comments to Airbus A300 Center Spar Sealing Angles Near Pylon Rear Attachment Fitting 

Inspection I Repair, left and right wings, Proposed Ruling; Docket No. FAA-2014-0282; 

Directorate Identifier 2012-NM-168-AD 

To Whom It May Concern: 

The Federal Aviation Administration released the subject NotiCe of Proposed Rulemaking (NPRM) for 

comments on May 9, 2014, via Federal Register Volume 79, Number 90, pp. 26651-26654. The NPRM 

proposes to supersede airworthiness directive (AD) 2006-07-07 and add a new AD to establish repetitive 

high frequency eddy current (HFEC) inspections of the left and right wing center spar sealing angles at 

Rib 8 and stringer 12 in accordance with Airbus SB A300-57-6027, Revision 07. United Parcel Service 

Co. (UPS) has concerns regarding the proposed ruling superse~ing AD 2006-07-07, use ofAverage Flight 

Time (AFT) methodology for mandatory action threshold and repetitive intervals, a numbering item I 

typographical error in paragraph ( o) and the added AD number documentation requirement for repair 

approval.· 

Th~ first comment regards the identified superseded airworthiness directive in the proposed rule. The 

proposed rule intent is to adjust the inspection intervals for the wing spar sealing angles in accordance 

·with Airbus SB A300-57-6027. Inspections per SB A300-57-6027 are currently mandated per AD 98-18-

02 whereas AD 2006-07-07, referenced in the proposed rule as being superseded, mandates a one-time 

accomplishment of Airbus SB A300-57 -6033 (mod no. 08609). UPS believes that AD 98-18-02 should be 

superseded and AD 2006·07 -07 remain as a standalone rule. This will address a potential conflict in the 

inspection accomplishment interval differences between AD 98-18-02 (SB A300-57-6027, Rev. 2) and 

NPRM 2012-NM-168-AD (SB A300-57-6027, Revision 7). 

The second comment deals with the compliance time I repeat inspectivn intervals and corrective action . 

requirements in paragraphs (i) through (m). The first item is paragraph (i) of this propose rule which 

identifies the initial and repeat inspection requirements. As service bulletin A300-57-6033 (mod no. 

08609) or repair drawings R57140588or R57150404 can be accomplished subsequent to aircraft service 

entry, the proposed rule distributes the task fe.quirements, accomplishment timeframe and any-exceptions 
over five separate paragraphs. This complexity could easily result in incorrect interpretation of the ruling 

requirements and is considered counterproductive to the rule issuance intent. For this item, UPS proposes 

to simplify and clarifying wording regarding the ruling requirements, task requirement and 

accomplishment timeframe, as shown in attachment 1. 

The second item concerns paragraph (j) which defines the inspection compliance times. The paragraph 

title is ."Initial Compliance Times" implying that any requirements for subsequent or repetitive actions 

will be defined elsewhere in the ruling requirements. UPS believes a more applicable paragraph title 

would be "Inspection Compliance Times". In addition to the paragraph title, the proposed rule identifies 

compliance tim~s for the inspection threshold and repeat intervals using the Average Flight Time (AFT) 

methodology. Review of prior FAA AD comments notes, including AD 98-18-02, that the FAA does not 

concur with the AFT compliance-time methodology as" ... such adjustments may not address the unsafe 

condition in a timely manner" and" ... they (AFT compliance times) dp not fit into the AD tracking 

process fo_r operators or for Principle Maintenance Inspectors (PMI's)' attempting to ascertain compliance 

with AD's." UPS shares the FAA concern with using the AFT compliance methodology. 

Under the proposed threshold for aircraft utilization equal to or less than 1.5 AFT value, the aircraft is 

flight cycle limited as the flight hour limit cannot be reached (reference Figure 1 ). In AFT> 1.5 situation, 

the aircraft is still flight cycle limited until an AFT value of 2.16 is achieved. As the flight hour limitation 

for an AFT value below 2.16 cannot be achieved, thus the flight hour limits add an unnecessary 

complexity to the threshold table and subsequent inspection actions. UPS believes that the use of a 

defined threshold and repeat inspection interval adequately provide for timely detection of possible 

damage. Use of the complex AFT methodology for determining inspection compliance timeframe 

requirements combined with the constant monitoring to ensure compliance with the proposed rule does 

not have the intended impact to enhance the safety or airworthiness of the aircraft. Instead, it provides an 

opportunity for errors to occur and places an undue burden on aircraft operators and the regulatory 

authority that monitors compliance. UPS believes a more consistent and simplified compliance 

requirement (i.e. defined threshold and repeat intervals) achieves the safety intent of this ruling and 

eliminates continuous AFT monitoring that is necessary to comply with the conditional AFT timelines in 

the proposed rule. 

The third item for the inspection and modification requirements are related to paragraphs (k) and (1). I 

Paragraph (k) refers to repairing per SB A300-57-6027 prior to further flight. The proposed wording 

limits the options to operators for a~dressing discrepancies found during the inspection process as there is 

no reference to Airbus SB A300-57-6033 or the two current repair drawings, R57140588 or R57150404. 

Paragraph (1) specifies. post modification actions and mandates contacting the FAA for "post repair" 

inspection requirements. UPS finds the paragraph title conflicting with the task requirement (modification 

versus repair) as well as the reference to Airbus SB A300-57-6027, SB A300-57-6027 only identifies an 

inspection procedure and refers the operator other Airbus documentation for corrective actiohs. In 

addition, the subsequent inspection requirements for the approved rework procedures per SB A300-57-

6033 (mod no. 08609) and repair drawings R57140588 or R57150404 are defined within SB A300-57-

6027, paragraph I.E.- Compliance. It is believed that the intent ofthis paragraph was to be applicable for 

repairs accomplished outside the scope of the noted three rework documents. To clarify this requirement, 

UPS proposes the wording as shown in attachment 1. 
Our third comment addresses a typographical error in paragraph ( o) ~Other FAA AD Provisions. In the 

noted paragraph, there are two provisions identified for this proposed rule numbered (1) Alternate 

Methods of Compliance and (3) Airworthy Product. UPS believes that the Airworthy Product paragraph 

should be identified as "(2)". 

Our final comment is in regards to the added AD number documentati'on requirement. In the proposed 

ruling "Determination and Requirements" section, the FAA contends that, " ... some US operators have . used repair instructions that were previously approved by a State of Design Authority or a Design 

Approval Holder (DAH) as a method of compliance with this provision in FAA Ads" and that, "Using 

repair instructions that were not specifically approvedfor a particular AD creates the potential for doing 

repairs that were not developed to address the unsafe condition ident!fied by the MCAI AD, the FAA AD, 

or the applicable service information, which could result in the unsafe condition not beingfit!ly 

corrected." To address this concern, the proposed ruling adds "For a repair method to be approved, the 

repair approval must spectfically refer to this AD" in paragraph (m)(l) of the 2012-NM-168-AD NPRM 

body. 

The proposed rule indicates that this change is due to the 'potential' for doing inadequate repairs. UPS 

believes that adding a reference to the applicable AD on repair documentation does not address the root 

cause of repair documentation availability. Previ9usly approved repairs for an AD affected area should 

have been vetted as part ofthe corrective action (SB issuance) and mandatory ruling development 

process. However, in the rare event that .a repair is not identified during this process, the operator is 

responsible for adherence to the "Airworthy Product" provision in the, ruling. I 

The "Airworthy Product" provision in conjunction with FAA Advisory Circular (AC) 120-77 provides 

sufficient guidance and clarification for compliance with repairs accomplished during the execution of 

compliance with a mandated ruling. Paragraphs 8.b.(2), S.c. 1 O.a.(2) and 13 all provide wording that 

identifies that an action (i.e. repair) must be shown to comply with the relevant airworthiness standards 

and that the type certificate standards are maintained. In the case of additional work beyond the scope of 

the mandated corrective action documentation (service bulletin, AOT, etc.), it is the operators 

responsibility to ensure the relevant airworthiness standards and type certificate standards are met prior to 

the aircraft or applicable component returns to service. 

UPS acknowledges that the rules governing the AD repair and deviation approval process for foreign 

manufactured aircraft differ from domestic built aircraft. We also believe that mandating the AD · 

reference on a rer)air will not address the issue that resulted in the proposed wording. UPS proposes to 

remove the proposed change from this particular NPRM paragraph (m)(l) as follows in addition to the 

proposed rule changes in Attachment 1: 

Paragraph (m)(l): 

" ... or the Design Approval Holder (DAH) with EASA design organization approval). For a repair 

method hJ be appro'lled, t!w repair approW:ll must specifically refer t9. this AD. " 

For the items I comments identified ab?ve, UPS recommends revising the proposed rule wording to 

provide an enhanced level of safety as shown in attaclunent 1. The proposed wording simplifies the 
compliance time requirements and clarifies the repair I rework options and subsequent post repair 

threshold and repeat inspection requ~rements. 

Thank you for your time in considerihg these comments. If further correspondence is required, please 

contact Mark Hilborn at (502) 329~6020. 

Sincerely,· 

UNITED PARCEL SERVICE CO. 

Edward M. Walton 

Director of Engineering 

EW:MRH:ss 

Attachment 

c: · Ed Walton 

Dan Haddix 

Bruce Nord 
FIGURE 1: NPRM 2012-NM-168-AD Inspection Threshold Determination using AFT Methodology 

NPRM 2012-NM-168-AD Initial Inspection Threshold 

0.9 1.0 1.1 1.2 1.3 1.4 1.5 1.6 1.7 1.8 1.9 2.0 2.1 2.2 2.3 

Average Flight Time (AFT) 

-Fit Cycles@ 20 000 FH & AFT< 1.5 -Fit Cycles@ 23 300 FH & AFT> 1.5 

-FC Limit (AFT< 1.5) -FC Limit (AFT> 1.5) 

Chart shows that for the flight hour threshold limits (23,300 FH for AFT <= 1.5 and 20,000 FH for AFT> 

1.5), the aircraft is flight cycle limited. For example, at an AFT value of 0.9, the aircraft will accumulate 

22,222 flight cycles when accumulating 20,000 flight hours. Thus the aircraft is limited by the flight cycle 

value. This is true until the AFT value= 2.16. 

Therefore, use of the AFT methodology does not provide any safety enhancement or timely detection of 

damage based on the aircraft historical utilization. 
Attachment 1: Proposed Wording for NPRM 2012-NM-168-AD 

Revise the NPRM Proposed Rule as follows: 

NOTE: Only the affected paragraphs are shown (proposed changes shown in italics font). Paragraph 

numbering changes are also shown in bold italics. 

2014-XX-XX Airbus lndustrie: 

(a) Effective Date 

This AD becomes effective <TED> 

(b) Affected ADs 

This AD supersedes AD 98-018-02, Amendment 39-10718 (FR 98-22818, August 26, 1998). 

(c) Applicability 

This AD applies to Airbus Model A300 B4-601, B4-603, B4-620, and B4-622, B4-605R and B4-

622R airplanes, Model A300 F4-605R and F4-622R airplanes, and Model A300 C4-605R Variant F 

airplanes, certificated in any category, except those on which Airbus Modification 8608 is 

incorporated in production. 

(d) Subject 

Air Transport Association (ATA) of America Code 57, Wings. 

(e) Reason 

This AD was prompted by reports that fatigue and damage tolerance analyses shows that the 

inspection threshold and interval must be reduced to allow timely detection of cracks on the sealing 

angles of the center spar, adjacent to rib 8. We are issuing this AD to prevent crack formation in the 

sealing angles; such cracks could rupture the sealing angle and lead to subsequent crack formation in 

the bottom skin of the wing, and resultant reduced structural integrity of the center spar section of the 

wmg. 

Paragraphs (g) (I) and (g)(2) of this AD restate the requirements for initial and repetitive inspections 

contained in paragraph (c) of AD 98-18-02. Therefore, for operators that have previously 

accomplished at least the initial inspection in accordance with AD 98-18-02, paragraph (g) of this 

AD require that the next scheduled inspection be pe1:{ormed within 5,100 landings or 9, OOO.flight 

hours, whichever occurs first, after the last inspection pe1:{ormed in accordance with paragraph (b) 

or (c) of AD 98-18-02, or within 5 00 landings afier the effective date of this AD, whichever occurs 

later. 

(f) Compliance 

You are responsible for having the actions required by this AD performed within the compliance 

times specified, unless the actions have already been done. 
(g) Retained Inspection Requirements 

(1) For those airplanes on which Airbus Modification 08609H5276 (Airbus Service Bulletin A300-

57-6033), or the mod~fication spec~fied in Airbus Repair Drawing R571-40588 or R571-40942, 

has not been accomplished: Perform HFEC inspections to detect cracks in the center spar sealing 

angles adjacent to Rib 8, in accordance with Airbus Industrie Service Bulletin A300-57-6027, 

Revision 2, dated September 13, 1994, at the later of the times spec~fied in paragraph (g)(l)(i) or 

(ii), as applicable, o.f this AD. Repeat the inspection thereafter at intervals not to exceed 6, 000 

landings or 12, 600flight hours, whichever occurs.first until the inspections required by 

paragraph (h) of this AD are accomplished. Afier the effective date o.f this AD, only Revision 7 o.f 

the service bulletin shall be used. 

(i) For airplanes on which HFEC inspections have not been accomplished in accordance with AD 

98-18-02: Prior to the accumulation o.f 10,600 total landings or 22,260 totalflight hours, 

whichever occurs.first. 

(ii) For airplanes on which HFEC inspections have been accomplished in accordance with AD 

98-18-02: Within 6, 000 landings or 12, 600flight hours, whichever occurs.first, after 

accomplishment o.f the last inspection pe1:{ormed in accordance with the requirements o.f 

paragraph (c) o.f AD 98-18-02. 

(2) For those airplanes on which Airbus Mod~fication 08609H5276 (Airbus Service Bulletin A300-

57-6033) or the modification specified in Airbus Repair Drawing R571- 40588 or R571-40942 

has been accomplished: Pe1:{orm a HFEC inspection to detect cracks in the center spar sealing 

angles adjacent to Rib 8, in accordance with Airbus Industrie Service Bulletin No. A300-57-

602 7, Revision 2, dated September 13, 1994, at the later o.f the times spec~fied in paragraph 

(g)(2)(i) or (g)(2)(ii), as applicable, o.f this AD. Repeat the inspection thereafter at intervals not to 

exceed 6, 000 landings or 12, 600.flight hours, whichever occurs.first until the inspections 

required by paragraph (h) o.f this AD are accomplished. After the effective date o.f this AD, only 

Revision 7 o.f the service bulletin shall be used. 

(i) For airplanes on which HFEC inspections have not been accornplished in accordance with AD 

98-18-02: Prior to the accumulation o.f 13,200 landings or 27, 720flight hours, whichever 

occurs.first, a:fier accomplishing the modification. 

(ii) For airplanes on which HFEC inspections have been accomplished in accordance with AD 

98-18-02: Within 6,000 landings or 12,600flight hours, whichever occursfirst, after 

accomplishment o_fthe last inspection performed in accordance with the requirements o.f 

paragraph (c) of AD 98-18-02. 

(h) New Inspection and Repair Requirements 

(1) For those airplanes on which Airbus Mod~fication 08609H5276 (Airbus Service Bulletin A300-

5 7-6033), or the modification specified in Airbus Repair Drawing R57140588 or R5 7140942, 

has not been accomplished: Pe1:{orm HFEC inspections to detect cracks in the center spar sealing 

angles adjacent to Rib 8, in accordance with Airbus Industrie Service Bulletin A300-57-6027, 

Revision 7, dated June 6, 2011, at the later o.f the times spec~fied in paragraph (h)(l)(i) or (ii), as 

applicable, and (iii) o.f this AD. Repeat the inspection thereafter at intervals not to exceed 5, I 00 

landings or 9, OOO.flight hours, whichever occurs.first. Accomplishment o.f these inspections 

terminates the requirements o.f paragraph (g) o.f this AD. 
(i) For airplanes on which HFEC inspections have not been accomplished in accordance with AD 

98-18-02: Prior to the accumulation of9,000 total landings or 15,900 totalflight hours, 

whichever occurs first. 

(ii) For airplanes on which HFEC inspections have been accomplished in accordance with AD 

98-18-02: Within 5,100 landings or 9,000flight hours, whichever occursfirst, after 

accomplishment of the last inspection performed in accordance with the requirements of 

paragraph (g) of this AD. 

(iii) Within 500 landings after the effective date of this AD. 

(2) For those ailplanes on which Airbus Mod~fication 08609H5276 (Airbus Service Bulletin A300-

57-6033) or the modification spec~fied in Airbus Repair Drawing R57140588 or R57140942 has 

been accomplished: Perform a HFEC inspection to detect cracks in the center spar sealing 

angles adjacent to Rib 8, in accordance with Airbus Industrie Service Bulletin No. A300-57-

6027, Revision 7, dated June 06, 2011, at the later of the times spec(fied in paragraph (h)(2)(i), 

(h)(2)(ii), (h)(2)(iii) or (h)(2)(iv), as applicable, and paragraph (h)(2)(v) of this AD. Repeat the 

inspection thereafter at intervals not to exceed 5,100 landings or 9, OOO.flight hours, whichever 

occurs .first. After the effective date of this AD, only Revision 7 of the service bulletin shall be 

used. Accomplishment of this inspection terminates the requirements of paragraph (g) of this AD. 

(i) For airplanes on which Airbus Modification 08609H5276 (Airbus Service Bulletin A300-57-

6033) or the mod(fication spec(fied in Airbus Repair Drawing R57140588 or R57140942 has 

been accomplished and HFEC inspections have not been accomplished in accordance with 

AD 98-18-02: Prior to the accumulation of 11,300 landings or 20,000flight hours, 

whichever occurs.first, afier accomplishing the mod(fication. 

(ii) For airplanes on which the mod(fication spec(fied in Airbus Repair Drawing R57150404 has 

been accomplished but R57150413 has not been accomplished and HFEC inspections have 

not been accomplished in accordance with AD 98-18-02: Prior to the accumulation of 

19,5 00 landings or 34,5 00 flight hours, whichever occurs.first, after accomplishing the 

mod(fication. 

(iii) For airplanes on which Airbus Mod(fication 08609H5276 (Airbus Service Bulletin A300-57-

6033) or the mod(fication spec(fied in Airbus Repair Drawing R57140588 or R57140942 has 

been accomplished and HFEC inspections have been accomplished in accordance with AD 

98-18-02: Within 5,100 landings or 9, OOO.flight hours, whichever occurs.first, after 

accomplishment of the last inspection pe1formed in accordance with the requirements of 

paragraph (h) of this AD. 

(iv) For airplanes on which the mod(fication spec~fied in Airbus Repair Drawing R57150404 has 

been accomplished but R57150413 has not been accomplished and HFEC inspections have 

been accomplished in accordance with AD 98-18-02: Within 5,100 landings or 9, OOO.flight 

hours, whichever occurs.first, afier accomplishment of the last inspection performed in 

accordance with the requirements o.f paragraph (h) o.f this AD. 

(v) Within 500 landings afier the 4fective date o.fthis AD. 

(3) If any crack is found in the center spar sealing angles, including cracking entirely through the 

sealing angle, during the inspections required by paragraph (g) or (h) o.f this AD: Prior to further 

flight, replace the pair o.f sealing angles on the affected wing and cold work the attachment holes, 
in accordance with Airbus Repair Drawing R57140589 or R57140942; and perform the 

repetitive inspections required by paragraph (h)(2) of this AD as applicable. 

(4) If any sealing angle is found to be cracked through entirely during the inspections required by 

paragraph (g) or (h) of this AD: Prior to .fitrtherflight, perform additional inspections to detect 

cracks in the adjacent butt strap and skin panel, in accordance with paragraph 3.B. of Airbus 

Industrie Service Bulletin AJ00-57-6027, Revision 7, dated June 06, 2011. If any crack isfound 

in the adjacent butt strap and skin panel, prior to.fitrtherflight, repair in accordance with Airbus 

Repair Drawing R57140611. 

(i) New Requirement of This AD: Corrective Action 

For airplanes on which the mod{fication spec{fied in Airbus Repair Drawing R57150404 has been 

accomplished and Airbus Repair Drawing R57150413 has or is scheduled to be accomplished, within 

6 months after the effective date of this AD, or before further flight after doing the modification, 

whichever occurs later, contact the FAA, ANM-116, Transport Airplane Directorate, or EASA (or its 

delegated agent, or the Design Approval Holder (DAH) with EASA design organization approval, as 

applicable) for repetitive post-repair inspections and corrective actions, and do those actions. 

NOTE: The proposed AD draft contained in Attachment 1 no longer requires the items previously 

contained in paragraph (m) of the proposed rule. The content is placed here for reference 

only. 

(m) Exeeptians ta the Serviee Bulletin 

(1) Where Note 01 and Note 02 ofparagraph I.E., "Compliance," of Airbus Service Bulletin A300 

57 6027, Revision 07, dated June 6, 2011, specifies to contact Airbus for inspection 

requirements, this AD requires, at the applicable compliance time specified in Table 1 and Table 

2 in the "Grace Period," column in paragraph I.E., "Compliance," of Airbus Service Bulletin 

i\300 57 6027, Revision 07, dated June 6, 2011, to repair using a method approved by the 

Manager, Intemational Branch, Al'll.4 116, Transport Airplane Directorate, FAA; or European 

Aviation Safety Agency (EASA) (or its delegated agent, or the Design Approval Holder (DAH) 

with EASA design organization approval, as applicable). For a repair method to be appro:ved, the 

repair approval must specifically refer to this AD. 

(2) Where the Airbus Service Bulletin A300 57 6027, Revision 07, dated June 6, 2011 specifies a 

compliance time in Table 1 and Table 2 in the ''Grace Period,'' column in paragraph I.E., 

"Compliance," this AD requires compliance within the specified compliance time after the 

effective date of this AD. 

(3) Where Table 1 and Table 2 in paragraph I.E., "Compliance," of Airbus Service Bulletin A300 

57 6027, Revision 07, dated June 6, 2011, specifies a choice between flight cycle or flight hours, 

this AD requires a compliance time within the specified flight cycles or flight hours, whichever 

occurs first. 

(4) Where Table 1 and Table 2 in paragraph I.E., "Compliance," of Airbus Service Bulletin A300 

57 6027, Revision 07, dated June 6, 2011, specifies pre modification 8609, this AD requires 

compliance '<Vithin the compliance time specified in the ''Threshold Inspection'' column. Those 

compliance times are flight cycles or flight hours since nev<'. 
(5) Where Table 1 and Table 2 in paragraph l.E., ''Compliance,'' of Airbus Service Bulletin A300 

57 6027, Revision 07, dated June 6, 2011, specifies any post modification or repair, this AD 

requires compliance within the compliance time specified in the 'Threshold Inspection" column. 

Those compliance times are flight cycles or flight hours since accomplishing the modification or 

repillr. 

(j) Credit for Previous Actions 

<No changes from proposed rule except for paragraph numbering> 

(k) Other FAA AD Provisions 

The following provisions also apply to this AD: 

(1) Alternative Methods of Compliance (AMOCs): <No changes from proposed rule > 

(2) Airworthy Product: <No changes from proposed rule except for sub-paragraph numbering> 

(I) Related Information 

<No changes from proposed rule exceptfor paragraph numbering>