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the multi‐district litigation; and an expert nominated by the Chemical Safety
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Board.

The members of the TWG provided DNV with input and suggestions for
testing protocols and other technical support. DNV held daily morning meetings
with the TWG to discuss each day’s planned forensic testing activities. Through
participation in morning meetings and observation of DNV’s work, TWG
members were able to monitor all day‐to‐day forensic testing activities.

G. Examination Methods Used by DNV

1. Forensic Testing Plan

At the request of the JIT, DNV developed and submitted for JIT approval
a forensic testing plan. The plan included forensic testing procedures for the
BOP stack and its components in accordance with established and accepted
protocols, methods, and techniques. DNV’s forensic testing plan was also
336
submitted to the TWG and the parties in interest (“PIIs”) for review and
comment. Where appropriate, DNV revised its test plans to address comments
received. The JIT approved DNV’s revised forensic testing plan on October 27,
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2010.

2. BOP Stack Testing

After the BOP stack arrived at the Michoud testing site, DNV visually
inspected the stack and recorded all visible numbers including serial numbers.
DNV examined internal components using a camera and video borescope. DNV
then completed the following tasks: (1) determination of the final position of the
annular preventers and rams; (2) examination of the condition of the BOP and
the LMRP; (3) removal of the drill pipe from the BOP and the LMRP; (4) removal

335 The U.S. Chemical Safety Board (“CSB”) is an independent federal agency charged with
investigating industrial chemical accidents.
336 The protocols included professional video recording of the entire examination and complete
photographic documentation.
337 The protocols in DNV’s forensic testing plan were not meant to be a step‐by‐step set of
procedures. As with many forensic examinations, the test plan provided a roadmap for meeting
the objectives, but needed to be adapted as the testing progressed. DNV submitted additional
protocols that were outside of the scope outlined in the original testing plan to TWG for review
and comment and to the JIT for approval.

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