Discussion
The EASA, which is the Technical Agent for the Member States of the European Union, has issued EASA AD 2018-0148R1, dated April 5, 2019 (``EASA AD 2018-0148R1'') (also referred to as the Mandatory Continuing Airworthiness Information, or ``the MCAI''), to correct an unsafe condition for all Airbus SAS Model A330-243, A330-243F, A330-341, A330- 342, and A330-343 airplanes.
The FAA issued a notice of proposed rulemaking (NPRM) to amend 14 CFR part 39 by adding an AD that would apply to all Airbus SAS Model A330-243, A330-243F, A330-341, A330-342, and A330-343 airplanes. The NPRM published in the Federal Register on June 26, 2019 (84 FR 30052). The NPRM was prompted by reports of TRU beams found with evidence of thermally caused material degradation in the rearmost section of the TRU beam at certain latches. The NPRM proposed to require an inspection for heat damage of each left-hand and right-hand TRU beam. The NPRM also proposed to require, depending on the findings, inspections of the TRU beam latches, the TRU beam clevises, and the thrust reverser outer fixed structure rear area; corrective actions; and replacement of TRU beams.
The FAA is issuing this AD to address degradation of TRU beams, which could lead to disconnection of the TRU from the engine, causing possible damage to the engine adjacent structure and controls and possible damage to the airplane. See the MCAI for additional background information.
Comments
The FAA gave the public the opportunity to participate in developing this final rule. The following presents the comments received on the NPRM and the FAA's response to each comment. Patrick Imperatrice expressed support for the NPRM.
Request To Allow Certain Substitutions
American Airlines identified several errors in the service information referenced in EASA AD 2018-0148R1, and requested correction of the errors through allowing certain substitutions. The commenter noted that the proposed AD requires compliance with EASA AD 2018- 0148R1, which in turn references service information from Airbus, Rolls Royce, and Safran. The commenter stated that the applicable service information contains several errors when referring to part numbers, documents, and the order in which certain steps are to be done. The commenter added that Safran verified these errors. Specifically, the commenter requested that the proposed AD be revised to allow the following substitutions:
The installation of NAS1149 series washers in lieu of AN960 washers.
The installation of NAS6303U4 bolts in lieu of NAS6303U04 bolts.
The use of NSA5050-4C nuts in lieu of NAS5050-4C nuts.
The reference to ``Airbus SRM 51-75'' in lieu of ``Rolls Royce SRM 54-02-04'' for paint restoration.
The reference to ``CMM 78-30-20 Figure 39 Graphic 78-30- 20-991-839-A01'' in lieu of ``CMM 78-30-20 Figure
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38 Graphic 78-30-20-991-838-A01'' for replacement of damaged right-handthrust reverser latch covers and hardware.
The allowance to de-energize the ground service network, as specified in aircraft maintenance manual (AMM) 24-42-00, after closing the fan cowl doors in lieu of de-energizing the ground service network before closing the fan cowl doors.
The FAA acknowledges the referenced errors and agrees with the commenter's request. The FAA has added paragraphs (h)(3) through (8) to this AD to include exceptions allowing the substitutions requested by the commenter.
Conclusion
The FAA reviewed the relevant data, considered the comments received, and determined that air safety and the public interest require adopting this final rule with the changes described previously and minor editorial changes. The FAA has determined that these minor changes:
Are consistent with the intent that was proposed in the NPRM for addressing the unsafe condition; and
Do not add any additional burden upon the public than was already proposed in the NPRM.The FAA also determined that these changes will not increase the economic burden on any operator or increase the scope of this final rule.
Related IBR Material Under 1 CFR part 51
EASA AD 2018-0148R1 describes procedures for a special detailed inspection for heat damage of each left-hand and right-hand TRU beam, detailed inspections of the TRU beam latches for bush migration and cracks or deformation, detailed inspections of the TRU beam clevises for cracks and deformation, ultrasonic inspections of the thrust reverser outer fixed structure rear area for delamination, replacement of TRU beams, and corrective actions. Corrective actions include restoring paint, repairing delaminated areas, and measuring latch pin hole fitting diameters near migrated bushes. This material is reasonably available because the interested parties have access to it through their normal course of business or by the means identified in the ADDRESSES section.
Costs of Compliance
The FAA estimates that this AD affects 51 airplanes of U.S. registry. The FAA estimates the following costs to comply with this AD:
Estimated Costs for Required Actions ----------------------------------------------------------------------------------------------------------------
Cost per Cost on U.S.
Labor cost Parts cost product operators ---------------------------------------------------------------------------------------------------------------- 1 work-hour x $85 per hour = $85............................. $0 $85 $4,335 ----------------------------------------------------------------------------------------------------------------
The FAA estimates the following costs to do any necessary on- condition actions that would be required based on the results of any required actions. The FAA has no way of determining the number of aircraft that might need these on-condition actions:
Estimated Costs of On-Condition Actions * ------------------------------------------------------------------------
Cost per
Labor cost Parts cost product ------------------------------------------------------------------------ 2 work-hours x $85 per hour = $170.... $0 $170 ------------------------------------------------------------------------
* The table only includes the costs for on-condition inspections. The
FAA has received no definitive data that would enable the agency to
provide cost estimates for the on-condition corrective actions and
replacement specified in this AD.
According to the manufacturer, some or all of the costs of this AD may be covered under warranty, thereby reducing the cost impact on affected individuals. The FAA does not control warranty coverage for affected individuals. As a result, the FAA has included all known costs in our cost estimate.
Authority for This Rulemaking
Title 49 of the United States Code specifies the FAA's authority to issue rules on aviation safety. Subtitle I, section 106, describes the authority of the FAA Administrator. Subtitle VII: Aviation Programs, describes in more detail the scope of the Agency's authority.
The FAA is issuing this rulemaking under the authority described in Subtitle VII, Part A, Subpart III, Section 44701: ``General requirements.'' Under that section, Congress charges the FAA with promoting safe flight of civil aircraft in air commerce by prescribing regulations for practices, methods, and procedures the Administrator finds necessary for safety in air commerce. This regulation is within the scope of that authority because it addresses an unsafe condition that is likely to exist or develop on products identified in this rulemaking action.
This AD is issued in accordance with authority delegated by the Executive Director, Aircraft Certification Service, as authorized by FAA Order 8000.51C. In accordance with that order, issuance of ADs is normally a function of the Compliance and Airworthiness Division, but during this transition period, the Executive Director has delegated the authority to issue ADs applicable to transport category airplanes and associated appliances to the Director of the System Oversight Division.
Regulatory Findings
This AD will not have federalism implications under Executive Order 13132. This AD will not have a substantial direct effect on the States, on the relationship between the national government and the States, or on the distribution of power and responsibilities among the various levels of government.
For the reasons discussed above, I certify that this AD:
(1) Is not a ``significant regulatory action'' under Executive Order 12866,
(2) Will not affect intrastate aviation in Alaska, and
(3) Will not have a significant economic impact, positive or negative, on a substantial number of small entities under the criteria of the RegulatoryFlexibility Act.
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List of Subjects in 14 CFR Part 39
Air transportation, Aircraft, Aviation safety, Incorporation by reference, Safety.