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 Avenue 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 ItMay Concern:
The Federal Aviation Administration released the subject NotiCe ofProposed 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 ofthe 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(o) and the added AD number documentation requirement for repair approval.·**Th~** first comment regards the identified superseded airworthiness directive in the proposed rule.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SB A300-57-6027 are currentlymandated per AD 98-18- 02 whereas AD 2006-07-07, referenced in the proposed rule as being superseded, mandates a one-time accomplishment ofAirbus SB A300-57-6033 (mod no. 08609). UPS believes that AD 98-18-02 should be superseded and AD 2006·07-07 remain as a standalone rule.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 Irepeat inspectivn intervals and corrective action

. requirements in paragraphs (i) through (m). The first item is paragraph (i) ofthis propose rule which identifies the initial and repeat inspection requirements. As service bulletin A300-57-6033 (mod no. 08609) orrepair drawings R57140588or R57150404 can be accomplished subsequent to aircraft service entry, the proposed rule distributes the task fe.quirements, accomplishment timeframe and any-exceptionsover five separate paragraphs. This complexity could easily result in incorrect interpretation ofthe ruling requirements and is considered counterproductive to the rule issuance intent. Forthis 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 ofprior FAAAD 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 of2.16 is achieved. As the flight hour limitation for an AFT value below 2.16 cannot be achieved, thus the flight hour limits add anunnecessary complexity to the threshold table and subsequent inspection actions. UPS believes that the use ofa defined threshold and repeat inspection interval adequately provide for timely detection ofpossible damage. Use ofthe 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 ofthe 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 ofthis 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. Theproposed 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 orR57150404. 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 requirementsfor the approved rework procedures per SB A300-57- 6033 (mod no. 08609) and repair drawings R57140588 orR57150404 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 ofthe 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 ofCompliance 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. Inthe proposed ruling "Determination and Requirements" section, the FAA contends that, "

...some US operators have



# . used repair instructions that werepreviously approved by a State of DesignAuthority ora Design ApprovalHolder (DAH) as a methodof compliance with thisprovision in FAA Ads" and that, "Using repair instructions that were notspecifically approvedfor aparticularAD creates the potential for doing repairs that were not developed to address the unsafe condition ident!fied by the MCAIAD, 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 mustspectfically refer to thisAD"in paragraph (m)(l) ofthe 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 ofrepair 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 ofadditional 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 particularNPRM paragraph (m)(l) as follows in addition to the proposed rule changes in Attachment 1:
Paragraph (m)(l): "

... orthe Design Approval Holder (DAH) with EASA design organization approval). For a repair method hJ be appro'lled, t!w repair approW:ll mustspecifically refer t9. thisAD. "

For the items I comments identified ab?ve, UPS recommends revising the proposed rule wording to provide an enhanced level ofsafety as shown in attaclunent 1. The proposed wording simplifies thecompliance 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. Iffurther correspondence is required, please contact Mark Hilborn at (502)**329~6020.** Sincerely,·

UNITED PARCEL SERVICE CO.

Edward M. Walton Director ofEngineering

EW:MRH:ss
Attachment

c: · Ed Walton Dan Haddix Bruce Nord

### FIGURE 1: NPRM2012-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) -FitCycles@ 20 000 FH &AFT< 1.5 -FitCycles@ 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 FHfor AFT> 1.5), the aircraft is flight cycle limited. For example, at an AFTvalue of0.9, 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 ofthe AFT methodology does not provide any safety enhancement ortimely 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-XXAirbus 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 C4-605RVariant F airplanes, certificated in any category, except those on which Airbus Modification 8608 is incorporated inproduction. (d) Subject Air Transport Association (ATA) ofAmerica Code 57, Wings. (e) Reason This AD was prompted byreports that fatigue and damage tolerance analyses shows that the inspection threshold and interval must be reduced to allow timely detection ofcracks on the sealing angles ofthe 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 ofthe wing, and resultant reduced structural integrity ofthe center spar section ofthe wmg. Paragraphs (g) (I) and (g)(2) of thisAD restate the requirements for initial and repetitive inspections contained inparagraph (c) of AD 98-18-02. Therefore,for operators that havepreviously accomplished at least the initial inspection in accordance with AD 98-18-02,paragraph (g) of this AD require that the nextscheduled inspection bepe1:{ormedwithin 5,100 landings or 9, OOO.flight hours, whichever occurs first, after the last inspectionpe1:{ormed in accordance withparagraph (b)

or (c) of AD 98-18-02, orwithin 500 landings afier the effective date of thisAD, 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) RetainedInspection Requirements (1) For those airplanes on whichAirbusModification 08609H5276 (Airbus Service BulletinA300- 57-6033), or the**mod~fication spec~fied**  in AirbusRepairDrawingR571-40588 orR571-40942, has not been accomplished: Perform HFEC inspections to detect cracks in the centersparsealing angles adjacent to Rib 8, in accordance withAirbusIndustrie Service Bulletin A300-57-6027, Revision 2, dated September 13, 1994, at the later of the times**spec~fied** inparagraph (g)(l)(i) or (ii), as applicable, o.f thisAD. 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 thisADare accomplished. Afier the effective date o.f thisAD, onlyRevision 7o.f the service bulletin shall be used. (i) For airplanes on which HFEC inspections have not been accomplished in accordance withAD 98-18-02: Prior to the accumulation o.f 10,600 total landings or22,260 totalflight hours, whichever occurs.first. (ii) For airplanes on which HFEC inspections have been accomplished in accordance withAD 98-18-02: Within 6, 000 landings or 12,600flight hours, whichever occurs.first, after accomplishment o.f the last inspectionpe1:{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 BulletinA300- 57-6033) or the modification specified in AirbusRepairDrawingR571- 40588 orR571-40942 has been accomplished: Pe1:{orm a HFEC inspection to detect cracks in the center sparsealing angles adjacent to Rib 8, in accordance with AirbusIndustrie Service Bulletin No. A300-57- 6027, Revision 2, dated September 13, 1994, at the later o.f the times**spec~fied** inparagraph (g)(2)(i) or (g)(2)(ii), as applicable, o.f thisAD. Repeat the inspection thereafter at intervals not to exceed 6, 000 landings or 12,600.flight hours, whichever occurs.first until the inspections required byparagraph (h) o.f this AD are accomplished. After the effective date o.f thisAD, only Revision 7o.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.f13,200 landings or27, 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 12,600flighthours, whichever occursfirst, after accomplishment o_fthe last inspectionperformed in accordance with the requirements o.f paragraph (c) of AD 98-18-02. (h) NewInspection andRepairRequirements (1) For those airplanes on which Airbus**Mod~fication** 08609H5276 (Airbus Service BulletinA300- 57-6033), or the modification specified in AirbusRepairDrawingR57140588 orR57140942, has not been accomplished: Pe1:{orm HFEC inspections to detect cracks in the center sparsealing angles adjacent to Rib 8, in accordance with AirbusIndustrie Service BulletinA300-57-6027, Revision 7, datedJune 6, 2011, at the later o.f the times**spec~fied** inparagraph (h)(l)(i) or (ii), as applicable, and (iii) o.f thisAD. Repeat the inspection thereafter at intervals not to exceed 5,I00 landings or 9, OOO.flight hours, whichever occurs.first. Accomplishment o.f these inspections terminates the requirements o.f paragraph (g) o.f thisAD.(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) Forairplanes on which HFEC inspections have been accomplished in accordance withAD 98-18-02: Within 5,100 landings or9,000flight hours, whichever occursfirst, after accomplishment of the last inspectionperformed in accordance with the requirements of paragraph (g) of thisAD. (iii) Within 500 landings after the effective date of thisAD. (2) For those ailplanes on whichAirbus**Mod~fication** 08609H5276 (Airbus Service BulletinA300- 57-6033) or the modification**spec~fied** in AirbusRepairDrawingR57140588 orR57140942 has been accomplished: Perform a HFEC inspection to detect cracks in the centersparsealing angles adjacent to Rib 8, in accordance with AirbusIndustrie Service BulletinNo. A300-57- 6027, Revision 7, datedJune 06, 2011, at the later of the times spec(fied inparagraph (h)(2)(i), (h)(2)(ii), (h)(2)(iii) or (h)(2)(iv), as applicable, andparagraph (h)(2)(v) of thisAD. 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 thisAD, onlyRevision 7of the service bulletin shall be used. Accomplishment of this inspection terminates the requirements of paragraph (g) of thisAD. (i) For airplanes on whichAirbusModification 08609H5276 (Airbus Service BulletinA300-57- 6033) or the mod(fication spec(fied in AirbusRepairDrawingR57140588 orR57140942 has been accomplishedandHFEC inspections have not been accomplished in accordance with AD 98-18-02: Prior to the accumulation of 11,300 landings or 20,000flighthours, whichever occurs.first, afier accomplishing the mod(fication. (ii) For airplanes on which the mod(fication spec(fied in AirbusRepairDrawingR57150404 has been accomplished butR57150413 has not been accomplishedandHFEC inspections have
not been accomplished in accordance withAD 98-18-02: Prior to the accumulation of 19,500 landings or 34,500 flight hours, whichever occurs.first, after accomplishing the mod(fication. (iii) Forairplanes on whichAirbusMod(fication 08609H5276 (Airbus Service BulletinA300-57- 6033) or the mod(fication spec(fied in AirbusRepairDrawingR57140588 orR57140942 has been accomplishedandHFEC inspections have been accomplished in accordance withAD 98-18-02: Within 5,100 landings or 9, OOO.flight hours, whichever occurs.first, after accomplishment of the last inspectionpe1formed in accordance with the requirements of paragraph (h) of thisAD. (iv) For airplanes on which the mod(fication**spec~fied** in AirbusRepairDrawingR57150404 has been accomplished butR57150413 has not been accomplishedandHFEC inspections have been accomplished in accordance withAD 98-18-02: Within 5,100 landings or9, OOO.flight hours, whichever occurs.first, afier accomplishment of the last inspectionperformed in accordance with the requirements o.f paragraph (h) o.f thisAD. (v) Within 500 landings afier the 4fective date o.fthisAD. (3) If any crack is found in the center sparsealingangles, including cracking entirely through the sealingangle, during the inspections required byparagraph (g) or (h) o.f thisAD: Prior tofurther flight, replace thepair o.f sealing angles on the affectedwingandcold workthe attachment holes,in accordance withAirbusRepairDrawingR57140589 orR57140942; andperform the repetitive inspections required byparagraph (h)(2) of thisAD as applicable. (4) If any sealingangle isfound to be cracked through entirely during the inspections required by paragraph (g) or (h) of thisAD: Prior to.fitrtherflight,perform additional inspections to detect cracks in the adjacent buttstrap andskinpanel, in accordance withparagraph 3.B. of Airbus Industrie Service BulletinAJ00-57-6027, Revision 7, datedJune 06, 2011. If any crack isfound in the adjacent butt strap andskinpanel,prior to.fitrtherflight, repair in accordance withAirbus RepairDrawingR57140611. 

### (i) NewRequirementof ThisAD: CorrectiveAction For airplanes on which the mod{fication spec{fied in AirbusRepairDrawingR57150404 has been accomplishedandAirbusRepairDrawingR57150413 has or is scheduled to be accomplished, within 6 months after the effective date of thisAD, or before further flight afterdoing the modification, whichever occurs later, contact the FAA, ANM-116, TransportAirplaneDirectorate, orEASA (or its delegated agent, or the Design ApprovalHolder (DAH) with EASA design organization approval, as applicable)for repetitivepost-repair inspections andcorrective actions, anddo those actions.



### NOTE: The proposed AD draft contained in Attachment 1 no longer requires the items previously contained in paragraph (m) ofthe 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," ofAirbus 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," ofAirbus 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 ''GracePeriod,'' column in paragraph I.E., "Compliance," this AD requires compliance within the specified compliance time after the effective date ofthis AD. (3) Where Table 1 and Table 2 in paragraph I.E., "Compliance," ofAirbus 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," ofAirbus 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 andTable 2 inparagraph l.E., ''Compliance,'' ofAirbus Service Bulletin A300 57 6027, Revision 07, dated June 6, 2011, specifies any post modification orrepair, 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 forPreviousActions <No changes fromproposed rule except forparagraph numbering> (k) OtherFAA ADProvisions The following provisions also apply to this AD: (1)AlternativeMethods of Compliance (AMOCs): <No changes fromproposed rule > (2)AirworthyProduct: <No changesfromproposed rule except for sub-paragraph numbering> (I) RelatedInformation <No changes fromproposed rule exceptforparagraph numbering>