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Between 1946 and 1958, Cold War tensions between the United States and the Soviet Union grew over issues such as Berlin, Korea, the Middle East, and the nuclear arms race. During this period, the United States conducted twenty-three nuclear explosions at Bikini Atoll in the Marshall Islands. These experiments contributed to the development of a powerful nuclear arsenal and strengthened the American strategy of deterrence, but they had devastating consequences for the people of Bikini and their environment. Like the Enewetakese, the Bikinians were displaced from their homeland and the ecology of their atoll was seriously damaged by the nuclear tests. To draw attention to their plight and gain compensation from the American government, the Bikinians fought back using methods similar to those employed by the people of Enewetak, including petitions, hearings, and lawsuits. In response to this pressure, the United States provided the islanders with various financial packages and encouraged them to return to their contaminated atoll. Although the return of the Bikinians provided American scientists with an opportunity to study the effects of prolonged human exposure to radiation, it resulted in serious health conditions. The islanders were left on Bikini for almost ten years before they had to be removed a second time due to the unsafe levels of radiation on the atoll. Afterward, the Bikinians continued to fight for justice, but Washington failed to supply enough funds to restore the ecology of their atoll or to adequately compensate them for the damages caused by the nuclear testing program.

In 1946, President Harry Truman’s decision to go ahead with Operation Crossroads, the first series of nuclear tests on Bikini Atoll, was reinforced by top military leaders, including Secretary of the Navy James Forrestal and Army Chief of StaffGeneral Dwight D. Eisenhower. On nationwide radio broadcasts, these influential officials argued that the tests on Bikini were necessary for “national defense” and to “save American lives.”1 As the United States began to develop a hardline containment policy against the Soviet Union, these leaders helped convince the American public that nuclear weapons tests were vital to national security.2

US military officials selected Bikini Atoll as a nuclear testing site for a variety of reasons. Like Enewetak, Bikini was already in the control of the United States and it was situated in a remote location in the Central Pacific Ocean, far from the continental United States.3 Comprising twenty-six islands, Bikini was about 250 miles from the airstrip on Kwajalein Atoll, and had enough land mass to support the necessary testing equipment and facilities. It also had a large, sheltered, lagoon of approximately 245 square miles for the anchorage of American ships. As well, Bikini had a small indigenous population that could be easily transported to another atoll. As Vice Admiral William Blandy explained, “It was important that the local population be small and co-operative so that they could be moved to a new location with a minimum of trouble.”4

On 10 February 1946, Navy Commodore Ben Wyatt, the American military governor of the Marshall Islands, informed the Bikinians that their atoll had been chosen as the site where the United States would test new and powerful weapons. Knowing that many of the Bikinians had been converted to Christianity, Wyatt told the people that they were “like the children of Israel whom the Lord saved from their enemy and led into the Promised Land.”5 He then asked the iroij of the atoll, Tomaki Juda, if he and his people would be willing to give up their atoll for the “benefit of all mankind and to end all world wars.”6

Soon after Wyatt made this presentation, the Bikinians agreed to the Americans’ request. According to Alab Lore Kessibuki, the people consented to leave their atoll because they were afraid of the United States and “didn’t feel we had any other choice but to obey the Americans.”7 During World War II, the Bikinians witnessed the power of the United States firsthand and were impressed by its decisive defeat of the Japanese, which included the dropping of atomic bombs on Hiroshima and Nagasaki. Furthermore, the Bikinians were led to believe that their move from Bikini would be temporary. Although the islanders were not provided with a specific deadline, the Americans gave the Bikinians the impression that they could return to their homeland once the United States no longer needed it as a nuclear testing site.8

According to the US Navy’s public statements, the “natives” of Bikini were “delighted” to be moving from their ancestral lands and “enthusiastic about the atom bomb, which has already brought them prosperity and a new promising future.”9 American officials offered the Bikinians the choice of moving to one of three other atolls in the Marshalls. Since two of these were already occupied, the Bikinians chose Rongerik, an uninhabited atoll, located 140 miles east of Bikini.10 Surrounded by the media, 167 Bikinians and their possessions were loaded on an

Figure 2.1.

Families transferring their homes from Bikini to Rongerik, 1946.

Department of the US Navy.

LST on 7 March 1946, less than a month after being told that they were to be moved. The navy assured them that Rongerik was actually a better place to live than Bikini: “Rongerik is about three times larger than Bikini…. Coconuts here are three or four times as large as those on Bikini and food is plentiful.”11

Prior to their removal, the islanders had relied almost exclusively upon Bikini’s land and lagoon for their food and material needs. Bound together by ties of kinship, they had developed a well-integrated society based on a close connection to the land. Under traditional Marshallese law and custom, each Bikinian was born with land rights in the islands of their atoll. These rights were intended to provide security to the members of the community. Because land in the Marshall Islands was scarce, the inhabitants did not regard it as a commodity that could be sold. Each individual was identified with the land that was perceived as his birthright, and ties to the land were therefore very strong.12

Despite the importance that the people of Bikini attached to their land, the United States formally established its control of the atoll through a use and occupancy agreement in April of 1946. For a sum of $10, the government of the Trust Territory of the Pacific Islands granted the United States the “exclusive right to use and occupy” all of the Bikini Atoll “for an indefinite period of time.” This document was signed by two American representatives, High Commissioner Delmas Nucker, on behalf of the TTPI government, and Navy Rear Admiral J. F. Jelley, on behalf of the United States.13 Significantly, no members of the Bikini Council were asked to sign the agreement.14

Once Washington established its formal control of Bikini through the use and occupancy agreement, the United States prepared the atoll for the Operation Crossroads series of nuclear tests, described as “the grandest scientific experiment ever.”15 The United States deployed 242 ships (70 of which were placed in the target area of the lagoon), 156 aircraft, 25,000 radiation recording devices, 42,000 military, scientific, and technical personnel and observers, and more than 5,000 animals to the Bikini Atoll.16

The main purpose of Operation Crossroads was to test the strength of the US Navy during an atomic attack. Due to the growing influence of the air force in planning related to nuclear weapons, the navy was keen to prove that it could play an important role in American postwar defense strategies.17 As the navy later described it, the goal of these tests was “to study the effects of nuclear weapons on ships, equipment and material.”18 In addition, thousands of live experimental animals were placed on the target ships to be exposed to radiation from the nuclear tests. For these experiments, American scientists utilized animals that shared similarities with humans, such as pigs and goats, so that they could gather information about the health effects of fallout on battleship crews.19

Most of the experimental animals were exposed when the first test of the series, 21-kiloton Able, was dropped from a B-29 bomber into the lagoon. Five ships were sunk by this explosion and, as Julianne Walsh explains, most of the animals “did not fare well.”20 Of the 3,619 experimental animals on the American ships, 656 of the animals were killed by the Able blast and more than 50 percent eventually died from radiation-related illnesses.21 Fewer animals were exposed during the second test, 21-kiloton Baker, but this underwater test had more spectacular environmental effects on Bikini Atoll. Jonathan Weisgall describes it as follows:

In one second, an underwater bomb pushed a one-mile-wide dome of water into the sky. Ten seconds later, as if in slow motion, the millions of tons of water and debris collapsed back into the lagoon, creating a gigantic curtain of mist and spray that moved outward at more than 60 miles an hour and soon engulfed almost all of the target ships. The blast, which sank the 26,000 ton battleship Arkansas in a matter of seconds, unleashed the greatest waves ever known to humanity…. It also unleashed the greatest amount of radioactivity ever known up to that time.22

Figure 2.2.

Shorn experimental goats before Able test, Bikini, 1946.

Defense Nuclear Agency.

Detonated 90 feet below the surface of the lagoon, Baker created a crater 700 yards wide and 20 feet deep.23 The heat from the blast was so extreme that it turned the water in the lagoon to steam, resulting in a massive die-off of fish and other marine organisms. The nine ships sunk by the explosion released oil into the lagoon that destroyed the coral, algae, and shellfish on the reef of Bikini. As well, the explosion contaminated the nearby land and marine life with large amounts of radioactivity. In total, the Baker shot dumped 500,000 tons of radioactive mud on the atoll’s islands and into the lagoon.24

While Operation Crossroads was taking place on their home atoll, the Bikinians remained displaced on Rongerik. Contrary to the navy’s claim, the islanders discovered that Rongerik was actually much smaller than Bikini. Whereas Bikini comprised twenty-six islands (2.9 square miles of land), Rongerik consisted of seventeen islands (0.6 square miles of land).25 The soil on Rongerik was also much less fertile than on Bikini and the lagoon considerably smaller. Within the first year of their arrival, it became apparent that food resources on Rongerik were insufficient. In July 1947 a medical officer who accompanied a field trip to Rongerik reported that the islanders were “visibly suffering from malnutrition.”26

Figure 2.3.

Underwater Baker test, Bikini, 1946.

Atomic Energy Commission.

The United States investigated the situation but no decisions were made to improve the Bikinians’ food supply or to move them elsewhere.27

At the end of January 1948, Leonard Mason, an anthropologist from the University of Hawai‘i, confirmed the “extreme state of impoverishment” that characterized the Bikinians’ situation on Rongerik. In particular, Mason noted the critical water shortage and lack of food on the atoll. All of the ripe pandanus and coconut fruits had long since been consumed and there was only one bag of flour left for the 167 people living on Rongerik. At night, the anthropologist reported, it was “difficult to sleep for the frequent crying of babies who were still hungry.” As a result, Mason requested emergency food rations and medical help for the Bikinians. When an American doctor arrived on Rongerik, he briefly examined the population and declared their condition “generally to be that of a starving people.”28

Given their dire situation on Rongerik, Mason recommended that the Bikinians be relocated as “soon as possible.”29 Shortly thereafter, the United States moved the islanders to Kwajalein, the largest atoll in the Marshalls, located approximately 200 miles southeast of Bikini. At the time, the Americans were in the process of transforming Kwajalein into a navy base and Marshallese workers had been recruited to work on its construction. Given Kwajalein’s designated purpose as a base, the Bikinians’ stay there was temporary; they lived on the atoll for seven months and then were moved again to the much smaller island of Kili, located approximately 280 miles southeast of Kwajalein.30

Only one-sixth the size of the Bikini atoll, Kili was a little over one mile in length and about one-quarter mile in width; it had a rich soil cover but no lagoon or sheltered area and poor feeding grounds for marine life. As Jack Tobin, the district anthropologist in the Marshall Islands, observed, “The change from an atoll existence [on Bikini] where marine resources were abundant and the lagoon and land areas stretched away as far as the eye could see, to a small, isolated island without a lagoon, and without the rich marine resources which are found in an atoll environment, was drastic.”31 With no protected anchorage for vessels, Kili also experienced heavy trade winds and rough seas from November until April of each year.32 These conditions made it impossible for the Bikinians to use their traditional outrigger sailing canoes for fishing beyond the island. As Weisgall reported, the skills the people had “developed for lagoon and ocean life at Bikini were useless on Kili.”33

Inadequate funding from the United States, combined with poor planning, resulted in few trust territory field trips to Kili Island.34 This shortage of field trips affected the Bikinians in a number of ways. Although coconut trees were growing on the island, the copra that the Bikini people produced on Kili was usually spoiled or eaten by rats by the time the next field ship arrived. In addition, food shortages, which occurred in 1949, 1950, and 1952, were so common that the Bikinians became convinced that Kili was another Rongerik. They came up with an expression for their new home, “Kili enana,” meaning “Kili is no good.”35

Due to their problems on Kili, the Bikinians desired to return to their home atoll. According to Delmas Nucker, the high commissioner, their return was impossible because the United States had the legal right to the atoll based on the 1946 use and occupancy agreement. Under pressure from US officials, in 1951 the islanders had also signed a document entitled “Release of Rights to Bikini Atoll” granting the high commissioner “all of the right, title and interest … to the Bikini Atoll.” In exchange, the Bikinians were given use rights to Kili Island and three islets of Jaluit Atoll located about thirty miles from Kili.36 Although thirteen Bikinian representatives were present (one iroij and twelve alabs) when the “release of rights” agreement was signed, only four signed the document and they did so without the benefit of legal counsel.37

While the Bikinians were forced to remain on Kili, the United States proceeded with its nuclear testing program on their home atoll. By 1954, the United States and the Soviet Union were engaged in a race to create the most powerful thermonuclear weapons.38 In an effort to maintain the American lead in this competition, the United States carried out Operation Castle, a series involving testing five nuclear bombs on Bikini Atoll.39 On March 1, the largest thermonuclear test ever conducted by the United States, code-named Bravo, was detonated on the surface of the reef in the northwestern corner of the Bikini Atoll. During the first minute, this explosion released energy equivalent to fifteen million tons of TNT, produced a huge fireball, created a massive crater in the coral reef, and stripped the nearby islands of all vegetation. Within ten minutes, a radioactive cloud formed that was sixty-five miles wide.40

Not surprisingly, the Bikinians and other Marshall Islanders were alarmed by the Castle tests. While the series was underway, the Marshallese sent a petition to the United Nations Trusteeship Council protesting against the tests. In this petition, sent on 20 April 1954, the Marshallese brought an “urgent plea” to the UN to get the tests stopped. As they pointed out, the United Nations was the appropriate organization of appeal due to its pledge to “safeguard the life, liberty, and general well-being of the Trust Territory.”41

The loss of their land to the United States government was a major concern to the petitioners; in the atoll environment, land was a scarce commodity necessary for sustenance and the Marshall Islanders deemed it their most precious resource. Land had both practical and spiritual meaning in Marshallese culture. As the petition stated, “Land means more than just a place where you can plant your food crops and build your houses; or a place you can bury your dead. It is the very life of the people. Take away their land and their spirits go also.”42

In their petition, the Marshallese asked the United States to stop testing nuclear weapons on their islands. They also requested compensation from Washington for the Bikinians and other communities who had been forced to relocate to different atolls.43 In its response, the State Department issued a carefully worded statement, jointly drafted by the Atomic Energy Commission and the Department

Map created by the Historical GIS Laboratory, University of Saskatchewan 2013

Note: Although the United States conducted twenty-three nuclear tests at Bikini Atoll, the author was unable to verify the site locations of the other twenty-two explosions.

WGS 1984 Martha Smith-Norris, Jessica DeWitt, and Geoff Cunfer

of Defense. According to this statement, it was very important for the Marshall Islanders to understand that the Eisenhower administration would not be conducting nuclear tests if it had not been determined, after very careful study, that they were required in the “interests of general peace and security.”44

In 1956, the United States made similar statements when it announced a new series of tests, Operation Redwing. According to the Atomic Energy Commission (AEC), the main goal of this series was to improve American military strength for the “purposes of peace.”45 In response, representatives for the Marshall Islanders sent another petition to the UN Trusteeship Council demanding that all nuclear experiments in the trust territory be stopped.46 Ignoring this request, the United States went ahead with Operation Redwing between May and July 1956. In total, this series included six large nuclear explosions on Bikini Atoll, with yields ranging from 365 kilotons to 5 megatons. One observer described Tewa, the biggest blast in the series: “Tewa had … the highest known [fission yield] of any US thermonuclear test, making it the “dirtiest” bomb ever…. The Bikini barge, site of ground zero, turned into a burning ball of fire and jumped up into the air alongside the mushroom cloud. After the blast, millions of dead fish floated on the surface for miles and miles alongside tens of thousands of dead birds, scooped up by live sharks and barracuda…. Fish also inhabited the tops of coconut palms that Tewa had not blasted apart.”47

While the Americans proceeded with Redwing, representatives from Kili went to Majuro to convey their grievances about living on the atoll to a UN visiting mission to the trust territory. One spokesman told the mission that he and the other Bikinians did not wish to live on Kili any longer.48 The Bikinians had suffered from starvation again in 1955 and the trust territory ships were still having trouble unloading food in the rough water around the island.49 If they could not be returned to their homeland, the Bikinians wanted to be moved elsewhere.50

In November 1956, the high commissioner, Delmas Nucker, visited Kili, where he was met by Magistrate Juda and “practically the entire population of the island.” During this meeting, Nucker offered the Bikinians a new deal: If they agreed to sign another paper giving the United States “full use rights” on Bikini Atoll, Washington would grant them similar rights on Kili as well as the islets on Jaluit atoll. As there was no lagoon on Kili and the amount of land on Kili and Jaluit was much smaller than on Bikini, the Americans were also willing to provide a financial package consisting of $325,000. Nucker made it clear that this money was being offered to pay for the use of the Bikini Atoll and “everything on it” for “as long as the [US] government needs to use it for the most good for the most people of the world.” Of the total amount, $25,000 would be given to the people of Bikini in cash and $300,000 set aside in a trust fund.51

According to the high commissioner, this agreement, which was necessary in the interests of “international peace and security,” would be honored by Washington until it no longer needed Bikini and the atoll could be safely returned to the people. Perhaps believing that this was the best deal that they could get, and, again, without the benefit of legal counsel, several Bikini alabs signed the “Agreement in Principle Regarding the Use of Bikini Atoll” on 22 November 1956.52 The Americans then gave the Bikinians $25,000 in one-dollar bills, to be divided equally among the people.53

While the Bikinians were forced to stay on Kili, the United States carried out its most extensive set of nuclear explosions in the spring and summer of 1958. This new series, “Hardtack I,” included detonations of ten nuclear weapons at Bikini, ranging in magnitude from 0.02 kilotons to 9.3 megatons.54 Not coincidentally, this flurry of explosions took place just prior to the American decision to call a moratorium on its nuclear testing program and participate in the nuclear test ban talks, which started in Geneva in October of 1958.55

Although the Eisenhower administration stopped testing nuclear weapons in the Marshall Islands in 1958, the people of Bikini remained displaced. In 1963 and 1964, the Bikinians sent petitions to Washington asking that they be resettled, preferably on their home atoll. They also had nagging questions about the 1956 agreement. Was it possible for them to go back to Bikini or had they given up the rights to their atoll for all time? If they were allowed to return to their homeland, would they forfeit the trust fund?56

As conditions continued to deteriorate on Kili, anthropologist Jack Tobin, who was also the community development adviser for the Marshall Islands, visited the island in 1968 to “ascertain the situation there.” While on Kili, Tobin observed that the shacks that the people lived in were falling apart and the water supply completely inadequate. Increasingly, the community was becoming anxious about the need to leave the island. “The anxiety level is very high on Killi [sic] now. The central thought is ‘when will we return to Bikini?’ It has become an obsession with these exiles. They have never given up the hope of returning to their home atoll. They have never become reconciled to living on Killi permanently. The situation is extremely tense and potentially explosive. I predict a dramatic and disruptive reaction if the Killi people are told that they cannot return to Bikini.”57

As a result of the deteriorating conditions on Kili, the Bikinians continued to pressure the Johnson administration to return them to their home atoll. Their return was problematic, however, due to the ecological condition of Bikini. A series of radiological surveys completed by the AEC indicated that Bikini Atoll remained contaminated. The results of a survey conducted in 1967 (based on gamma-ray spectrometry) showed that “a dose gradient [of radiation] existed across Bikini, with lowest levels on the beach areas, and highest values in the heavily overgrown interior.”58 Samples of local plants and animals, which were collected at Bikini and Eneu islands during the survey, also revealed the presence of radionuclides such as cesium-137 and strontium-90.59

Despite these findings, Dr. Robert Conard of the Brookhaven National Laboratory (BNL) and other members of an ad hoc committee assembled by the AEC recommended that the Bikinians be resettled on Bikini and Eneu islands. By this time, Conard had already carried out extensive studies on the effects of radiation on the people of Rongelap who had been repatriated to their contaminated atoll in 1957. Although these studies showed that the Rongelapese were suffering from negative health effects related to both internal and external exposure to radioactivity, the AEC concluded in 1968 that “the exposures to radiation that would result from the repatriation of the Bikini people do not offer a significant threat to their health and safety.”60

Figure 2.4.

Radioactive coconut crab, Bikini Survey, 1964.

University of Washington.

In July 1968, Jack Tobin participated in a radio conference with the Kili magistrate, Lore Kessibuki. The magistrate highlighted the islanders’ need for the over-due money from their trust fund and their urgent desire to return to Bikini. As Kessibuki explained, “The Kili people want to know when they can move back to Bikini. This is a question that the people think about night and day, every day, and every night.”61

Influenced by the AEC’s recommendations and the growing unrest on Kili, President Lyndon Johnson announced in August 1968 that Bikini and Eneu islands would be cleaned up and prepared for resettlement. According to a White House press release, Bikini Atoll was “again safe for habitation” and the United States was resolved to “work with the Bikini people in building a modern and model community on their atoll.”62 Elated at hearing this news, the 540 Bikinians living on Kili (and other islands and atolls such as Ebeye and Majuro) looked forward to returning home. Several weeks after the president’s announcement, a delegation of islanders was taken to Bikini Atoll for a visit. But as anthropologist Robert Kiste points out, they were shocked by what they saw. “Bikini was not the idyllic homeland of their memories. A massive amount of debris and equipment left from the tests cluttered the islands and the beaches. As a result of the nuclear experiments, two or three small islands and portions of others had disappeared. Most coconut palms and other plants of economic value had been removed or destroyed, and the atoll was engulfed by a dense layer of scrub vegetation.”63

Given the extensive damage caused by nuclear tests, the new Nixon administration prepared an eight-year plan for the rehabilitation and resettlement of Bikini.64 In early 1969, the Department of Defense was made responsible for the first phase of the plan, which involved the clearing of radioactive debris from Bikini Island.65 The US trust territory government and the Department of Interior were put in charge of the second phase, which included the replanting of coconut trees, the construction of housing, and the resettlement of the Bikinians from Kili.66

The AEC was given responsibility for the “radiological safety” of Bikini and Eneu islands. Significantly, the agency appointed Dr. Conard to conduct “medical surveillance” of the Bikinians as they returned to their home atoll.67 When asked about the risks involved in the resettlement of the Bikinians on their contaminated islands, Conard offered reassurance during an interview on the atoll: “Radiation levels on Bikini are so very slight and so many precautions have been taken to reduce the levels to extremely low amounts that there should not be any real hazard when these people are returned. We know from our experiences on Rongelap that the low levels of radiation there that persisted in the soil after the fallout were insufficient to cause any hazard to the Rongelap people so I wouldn’t expect that there would be any hazard here [on Bikini].”68

Given his extensive knowledge of the Rongelapese experience, this statement was a very odd one for Conard to make. Since 1954, Conard and other scientists working for the BNL had been conducting research studies on the Rongelapese, an atoll community located approximately one hundred miles east of Bikini, who had been exposed to large doses of radiation from the Bravo nuclear test. Based on these studies, Conard knew that the body burdens of radionuclides such as cesium-137 and strontium-90 increased dramatically after the Rongelapese (and a control group) were returned to their contaminated atoll.69 By the 1960s, Conard’s own reports also indicated that the Rongelapese were experiencing a number of serious health conditions related to their exposure to radiation such as thyroid cancer, birth defects, and growth retardation.70

Despite the health hazards, the return of the Bikinians to their contaminated atoll provided Conard with another opportunity to study the movement of radioisotopes “from the environment to man.”71 In preparation for the Bikinians’ return to their home atoll, the AEC carried out a radiological survey of the groundwater, animals, and soils of Bikini and Eneu islands. Led by Edward Held of the AEC, this survey (like an earlier one completed in 1967) showed that the well water on the two islands was contaminated with radioactive tritium, while food items such as coconut crabs, sea birds, and reef fish contained the radionuclides cesium-137, strontium-90, and plutonium-239 and-240. The soil also contained these four radionuclides, as well as iron-55, cobalt-60, and antimony 125.72 According to Held, these radionuclides would be available to any land animals living on the islands through the ingestion of the vegetation, other animals, or the soil.73 Given rapid advances in the technology of detection, combined with the long-lived nature of most of these fission products, Held concluded that “Bikini can be expected to remain a useful area for the study of the redistribution of radionuclides for at least several decades.”74

In addition to gaining data about the radiological condition of Bikini and Eneu islands, the AEC also gathered scientific information from the Bikinians in 1969. To obtain baseline data for his medical study of the Bikinians, Conard and his team collected urine samples from fourteen people living on Kili.75 After examining these samples in New York, the BNL concluded that the Bikinians had body burdens of cesium-137 and strontium-90 that were significantly lower than those in the people living on Rongelap at the time. Since Conard expected the levels of these radioisotopes to rise once the Bikinians returned to their contaminated atoll, he planned to conduct further tests on them, including whole-body gamma spectroscopy. He predicted, however, that the increase in the Bikinians’ body burdens of cesium-137 and strontium-90 would not be “anywhere near that measured in the Rongelap people on return to their island.”76

In 1969, thirty-one Bikinians were moved to Eneu Island, ostensibly to begin working on the rehabilitation of Bikini Island. Although Conard decided not to provide the islanders with medical examinations, he and his Brookhaven team began annual radiological monitoring of the Bikinians using urine analysis and whole-body counting.77 The scientists also assured the islanders that it was safe to eat the food and drink the water on Bikini and Eneu islands.78 Based on instructions from the Americans, the Bikinians dug wells to provide water for the new trees that they were planting on the atoll. They also used the water for drinking, to cook food, to clean their clothes, and to wash themselves.79 According to a Bikinian named Pero Joel, the workers ate the food on the islands as well:

On Eneu we had gardens and on Bikini we drank coconuts and ate pandanus all the time. I was one of the people helping to make those gardens. We were told in the beginning of our stay on Bikini that it was safe to eat anything we wanted, so we did. We had many kinds of foods, bananas and things like that. The scientists would come and explain a little about radiation, but we were always under the impression that everything was safe and that we could go about our everyday business and not worry. I used to ask them a lot of questions like, “How deep into the soil did the poison [radiation] go?” When they would answer they would say that it was about one-foot deep into the ground, but that it wasn’t anything for us to worry about.80

Meanwhile, the Bikinians remaining on Kili continued to draw attention to their plight. In December 1969, Lore Kessibuki, the magistrate of Kili, sent a letter to the new high commissioner, Edward Johnston, outlining many of their grievances. Since the planting stage of the rehabilitation program had just begun on Bikini, it was obvious that the remaining people on Kili would not be able to return to their home atoll any time soon. This situation was unacceptable since the living conditions on Kili continued to worsen:

Kili is like a prison and unsuitable as a place for people to live. Our suffering on Kili is too much to endure any longer. From the months of October through February, we are unable to be serviced by ships because of surf conditions. Our copra rots on the island and we cannot buy supplies. What little fish there are cannot be caught because of the giant waves…. Our houses are falling down around us…. We are starving during the winter months. Is this the way the United States treats people who have sacrificed everything to help America with her research?81

Kessibuki requested that the United States pay compensation for the suffering inflicted by the removal of the Bikinians to the atoll. In addition to starvation and humiliation, the relocation caused the islanders to become increasingly dependent on the trust territory government. As well, the people of Bikini viewed the 1956 agreement as “illegal” because they were not provided with legal counsel when the document was signed. The magistrate also highlighted the damage caused by the twenty-three nuclear tests on Bikini. In particular, he emphasized the “disappearance” of some islands and the dangerous levels of radiation on others. As he pointed out, “Coconut crabs, once a part of our diet, are radioactive.” To compensate the Bikinians for the use of their atoll, their relocation, and all of the damages caused by the nuclear testing program, Kessibuki demanded that Washington pay them $100 million.82

When the office of the high commissioner failed to respond to the magistrate’s letter, the Kili Council sent an urgent telegram to Jack Tobin in late February 1970. In this dispatch, the islanders demanded that “WE BE MOVED TO BIKINI IMMEDIATELY. WE DO NOT WISH TO REMAIN ON KILI ANY LONGER.” In a telephone conference on 2 March 1970, Kessibuki explained that approximately 550 islanders desired to return to the home atoll en masse (approximately 370 were living on Kili and 180 elsewhere, mostly on Ebeye and Majuro). The magistrate also repeated their demand for $100 million for the “damage to their land on Bikini, and the personal hardships caused by their removal from Bikini by the [US] Government.”83

In a memo to the high commissioner, Tobin warned that the islanders were becoming increasingly restive and frustrated, a situation exacerbated by the poor living conditions and lack of food on Kili. If the United States refused to return them to Bikini, Tobin predicted that the islanders would continue to bombard Johnston with verbal requests and possibly send another petition to the United Nations. More seriously, he expected that they would carry out a more overt and dramatic form of protest, such as a “boat in” to Bikini or a major demonstration at Majuro.84

In his correspondence with the Department of the Interior, High Commissioner Johnston conveyed little sympathy for the Bikinians’ situation. While Johnston conceded that it was “apparently true,” as Kessibuki had contended, “that the people were not represented by counsel” when the 1956 agreement was signed, the people of Bikini had had “more than sufficient time to obtain counsel” since that date. Based on the 1956 agreement and the earlier 1951 “release of rights” document, he argued, the Americans possessed full use rights of Bikini Atoll. Indeed, according to the high commissioner, the United States “had complete rights to destroy portions of it [Bikini Atoll] in the testing of nuclear weapons.” Furthermore, since a “substantial sum” had already been paid to the islanders in 1956, Washington felt no legal obligation to make any additional payment for the damages to Bikini Atoll or their displacement to Kili.85

Without consulting the Bikinians, the United States then signed an agreement returning most of Bikini Atoll to the TTPI government. On 4 May 1970, the high commissioner sent a letter to the Kili Council informing them that the US government had signed the document two weeks earlier. This agreement, with some minor exceptions, terminated the use and occupancy that had been granted to the Americans by the TTPI government in 1946.86 When they received this news, the Kili Council responded angrily. According to their leaders, the high commissioner had given his word that Bikini would be legally returned to them as soon as the trust territory regained control of it. As the council explained in a letter to Johnston, “We are disappointed we are not consulted before matters of importance are decided and that the High Commissioner promised to return Bikini to us as soon as he had authority to do so but this has not yet been done.”87

As a result of the continuing discontent expressed by the Bikinians, the attorney general of the trust territory, Robert Hefner, met with Magistrate Kessibuki and various members of the Kili Council on 4 March 1971. During this meeting, which took place at Majuro Atoll, the Bikinians described the hardships of living on Kili and their need for additional financial resources. More specifically, they requested an amendment to the 1956 trust fund agreement that would give them greater earning power and more flexibility.88 The Bikinians also asked for additional money to compensate them for the damage to Bikini and their relocation to Kili.89

Based on the Bikinians’ demands, Hefner suggested that the United States make some minor adjustments to the 1956 agreement. The attorney general also advised the US Congress to pay the islanders an additional $1 million in trust money to “alleviate the living conditions on Kili.” If the government did not provide this financial assistance, Hefner warned, the Kili Council undoubtedly would send more petitions to the United States and the United Nations, which would “embarrass us before the world community.”90

Responding to Hefner’s advice, High Commissioner Johnston signed an amendment to the 1956 trust agreement that gave the Bikinians more flexibility regarding their investments.91 However, Johnston was not as forthcoming regarding the Bikinians’ request for further financial compensation. As a result, the Kili Council decided to hire legal counsel to put more pressure on Washington. In a statement of grievances presented to the Nixon administration in 1973, their lawyers pointed out that the income derived from the trust fund granted in 1956 was insufficient, amounting to “no more than a pittance” when divided among the Bikini people twice a year, totaling only about $12.00 for each person. More broadly, the islanders wanted to remind the United States that:

The people of Bikini … have endured endless broken promises; three forced relocations of their homes; malnutrition and near-starvation; atomic destruction of their homeland and irradiation of their soil; deterioration of their social structure and loss of a sense of community; loss of many skills required for fishing on an atoll; isolation and rejection by the [trust territory] government; and the certain risk of living with the dangers of radioactivity. For all of this they have received a trust fund that loses money, some surplus USDA food and an isolated and miserable island far from their home. Surely the United States will not ignore their rights and complaints.92

The following year, the Kili Council demanded that the US Congress provide an ex gratia payment of $3 million. From the Bikinians’ perspective, this request was reasonable because the people of Enewetak had received similar compensation from the United States in 1969. The Bikinians justified this amount of money based on their twenty-seven years of suffering and hardship on Kili.93 In Tobin’s view, the islanders had “valid reasons” for claiming compensation from the US government, as he explained in a letter to the high commissioner:

In my view, as one who has been very close to the problems of the displaced Bikini People, … they have definitely and obviously not been adequately compensated for the loss of their homeland for so many years and the damage that has been done to it…. They were not dealt with equitably…. The returns to the United States from the use of Bikini … in terms of strategic military position, political power, and the acquisition of scientific and military knowledge have been incalculable. The returns to the exiled Bikini … People have been meagre.94

Working on behalf of the Bikinians, lawyers from the Micronesian Legal Services Corporation (MLSC) sent letters to the Department of the Interior and to the high commissioner to request compensation.95 Three members of the council also went to Washington to petition officials in the departments of Defense and Interior.96 Eventually, the pressure brought by the Bikinians and others paid off. Agreeing that the islanders’ petition97 was justified, the US Congress passed Public Law 94-34, the Hawaiian Trust Fund for the People of Bikini. Under this law, Washington provided a $3 million ex gratia payment “in recognition of the hardship suffered by the people of Bikini due to displacement from their atoll since 1946.”98

While the Bikinians remained displaced on Kili, the rehabilitation project on their home atoll proceeded at a sluggish pace. According to one report, the equipment used for cleanup and construction purposes on Bikini was “in such poor condition that work had been slowed down.”99 Since the United States had withdrawn its military personnel from Bikini, weekly air service between the atoll and Kwajalein had ended. This lack of air service, combined with a small number of boats—there were only three and all were in poor condition—meant that the agricultural and construction projects were behind schedule.100 According to the Bikinians, the work done by the housing contractor selected by the TTPI government was sloppy and characterized by continuous delays.101

As a result of these ongoing problems, the Kili Council voted not to return the remaining islanders to the home atoll. By this time, though, three extended families had already moved back to Bikini Island and were living in some of the newly constructed houses.102 But the radiological safety of these homes was in doubt. Based on a quick trip to the island, Dr. Martin Biles of the AEC wrote a favorable report, noting that “the reduction of radiation levels inside these houses meets our most optimistic estimates with inside levels half to one-third those outside.”103 However, as the legal representatives for the Bikinians explained in 1973, “It is uncertain—in spite of AEC statements to the contrary—that residence there will be safe. There is still a question of radioactive danger, as evidenced by the fact that the AEC required four-inch concrete floors in the Bikini houses.”104

Despite the per sis tent evidence of contamination, the Department of the Interior reported that forty “model” houses had been built on Bikini Island and approximately eighty people were living in them. In addition, over 80,000 coconut trees planted on Bikini and Eneu islands were “beginning to reach bearing age.” Overall, about 50 percent of the rehabilitation program was completed by early 1974.105

In March of that year, researchers from the Brookhaven National Laboratory arrived to conduct examinations of the people who had resettled on Bikini Island. Led by Dr. Conard, these scientists examined the levels of radioactivity in the residents on Bikini using urine samples and whole-body counting.106 As well, the scientists analyzed various food items and “general radiation on the island.” Afterward, Conard sent a very positive report to Oscar deBrum, the Marshallese district administrator. In this letter, the doctor reported that “the people living on Bikini have very low levels of radioactivity in their bodies” and the “radiation levels on the island are also low.”107

Despite Conard’s reassuring report, the AEC advised that a more sophisticated follow-up study be conducted by the Energy Research and Development Administration (ERDA), which had recently assumed AEC functions regarding Bikini. After receiving this recommendation, the Department of the Interior called a temporary halt to the resettlement and construction activities on Bikini.108 In March 1975, the secretary of the interior, Roger Morton, wrote a strongly worded letter to the secretary of defense explaining that the ERDA was prepared to conduct a thorough radiological survey of Bikini in April if DOD would provide the necessary logistical and financial support. As Morton put it: “Since the situation has potentially serious political implications for the US government and the Administration [ERDA], I strongly request that you consider providing the necessary support from Department of Defense resources.”109

But, in May 1975, the DOD rejected Interior’s request for the support needed for the new survey.110 Given the lack of cooperation from the DOD, combined with continued pressure from the Bikinians to resume the resettlement project, the ERDA conducted an intensive ground radiological survey of Bikini Island in June 1975, which resulted in some important discoveries.111 In contrast to Conard’s positive conclusions, the ERDA reported that people living on Bikini Island might receive radiation exposures above acceptable standards depending on where they lived on the atoll and what foods they ate. Since exposure estimates for the people living in the interior of the island were the highest, the ERDA advised that no additional houses be built in that area. In addition, the report concluded that certain staple foods grown on the island, such as pandanus, breadfruit, banana, papaya, and coconut crabs, not be eaten. The ERDA also recommended that well water on Bikini Island be used for agriculture only.112 The Department of Interior summarized the report:

In June 1975 an intensive ground radiological survey was conducted by the ERDA and it revealed that the original recommendations concerning resettlement on Bikini Island needed major revision. It became evident that the radionuclide intake in the plant food chain had been significantly miscalculated in terms of human consumption…. The survey demonstrated conclusively that the interior of Bikini Island should not be used for residential purposes; that well water should not be used for human consumption; and that locally grown food be placed on a restricted basis as far as consumption by the people is concerned.113

On 24 October 1975, the Bikinians’ legal counsels, George Allen and Ed King (both of the MLSC), met with Fred Zeder, the director of territorial affairs in Saipan. According to the lawyers, the Bikinians were very dissatisfied with Conard’s work: “The people have lost confidence in the doctor.” Based on the ERDA’s assessment in June, the islanders also had serious concerns about the radiation levels on their home atoll.114 As a result, Oscar deBrum wrote a strong letter to the high commissioner recommending that the people be moved from Bikini Island to another island on the atoll with less radiation.115

In addition, the Bikinians sent a petition to the US Congress demanding a radiation survey of Bikini “at the earliest possible date.” They also requested in dependent scientific analysis of the survey once it was completed, in order to make informed decisions regarding their “future location and the homes for ourselves and our children.” If the scientists concluded that their home atoll was unsafe, the Bikinians wanted the United States to help them resettle elsewhere in the Marshall Islands. In addition, they demanded another $1.5 million in compensation for the approximately 500 people residing on Kili who needed money for food, housing, and other family expenses.116

The Bikinians’ concerns about the safety of their atoll were valid. By 1976, it was increasingly evident that living on Bikini Atoll was a health hazard. In September of that year, the Lawrence Livermore National Laboratory (LLNL) prepared a report for the ERDA that assessed the amount of plutonium in the bodies of the Bikinians who were residing on the atoll. Contrary to Conard’s assurances about the “low levels of radioactivity in their bodies,” urine samples taken annually from the Bikinians between 1970 and 1975 revealed significant increases in their body burdens of plutonium. Using a population in New York as a control group, the study found that the Bikinians had ten times as much plutonium in their bodies as the Americans. Although some of the plutonium was entering the bodies of the Bikinians through inhalation from the air and soil, most of it was being ingested from contaminated food and water on the atoll. Samples from food grown on Bikini, such as papaya and pig muscle, for example, had concentrations of plutonium 100 times larger than similar food products in the New York diet. Given the toxicity of plutonium and its tendency to reside in the liver, bones, and lymph nodes of humans, these findings were “cause for concern.” Nevertheless, the study of the Bikinians provided the United States with a unique opportunity to learn more about the “metabolism of plutonium in the body.” In 1976, the authors of the report concluded: “Bikini Atoll may be the only global source of data on humans where intake via ingestion is thought to contribute the major fraction of the plutonium body burden. It is possibly the best available source of data for evaluating the transfer of plutonium across the gut wall after being incorporated into biological systems…. It appears that the transfer across the gut wall of plutonium incorporated into food products is greater than previously expected.”117

Tests conducted by American scientists on Bikini in 1977 also revealed unsafe levels of other radionuclides on the atoll. As the acting director of territorial affairs, George Milner, explained in a report to the high commissioner regarding the “Health of the People of Bikini Island,” the level of radioactive strontium-90 in the well water of the island exceeded acceptable US standards. As well, a number of foods being consumed by the Bikinians, such as breadfruit, pandanus, and coconuts contained unsafe levels of cesium-137. The health of the islanders was at risk given “the recycling of radionuclides by the plant life” and the “higher intake [of radionuclides] by the residents who are eating local produce.”118

Despite these findings, Dr. Conard claimed that there was “no immediate danger to the present residents” on Bikini Island. While he recognized that the presence of available food on the island was “an irresistible temptation, especially in the children,” Conard recommended that the Bikinians cease eating all locally grown produce and instead rely on an “increased subsidization of food by the Administration.”119 However, the Bikinians were increasingly uneasy about remaining on their island. Based on his experience as the BNL’s resident physician in the Marshall Islands, Dr. Konrad Kotrady reported in 1977 that “The people living at Bikini fear the ‘poison’ (radiation) that might be lingering on the island.” In particular, the islanders were concerned about the potential danger of secondary doses of radiation received from eating the local food, drinking the water, and living on the contaminated soil. According to Kotrady, the people failed to understand how Conard and the other scientists could know that “plutonium and other lingering radiation exists on the island such that some foods cannot be eaten, and then tell the people there is no danger.”120 Some Bikinians were coming to the conclusion that they had been moved back to their island as “guinea pigs” so that American scientists could measure the long-term effects of human exposure to radioactive fallout during the Cold War.121

Despite the increasing health risks, the Department of Energy, which had replaced the Atomic Energy Commission in 1977, left the islanders on Bikini for another year. While this decision posed an obvious health hazard to the families living there, it provided the BNL with an opportunity to acquire more research data about the effects of human exposure to radioactivity. Of the approximately eighty people living on Bikini Island in 1977, thirty-four were children, aged twelve years and under.122

In April 1978, a US medical team from the BNL arrived to conduct examinations on the people living on the island.123 Apparently still not understanding the full health risks involved, the Bikinians offered the American visitors coconuts as a sign of friendship. When the doctors completed their examinations of the islanders—using urine analyses and whole-body counting—they discovered “a continuing increase in body burdens of these radionuclides [strontium-90 and cesium-137] to levels that were considered unacceptable.”124 In one year, the amounts of cesium-137 in the islanders’ bodies had risen 75 percent, leading the AEC doctors to conclude that “the Bikinians had likely ingested the largest amounts of radiation of any known population.”125

During a later interview, the health physicist in the AEC’s Division of Biology and Medicine, Gordon Dunning, admitted that the agency made a serious mistake when it declared Bikini Atoll safe for rehabitation in 1968. In estimating the dose of radiation that the resettled islanders would ingest by eating the food on Bikini, he argued, the AEC had relied on a 1957 report, based on the diet of the Rongelapese that assumed a daily consumption of only nine grams of coconut. According to Dunning, this was a gross error off by a factor of about one hundred. “We just plain goofed,” he told Weisgall.126

What Dunning failed to point out, however, was that a report completed by the AEC on the diet of the returning Enewetak population estimated a daily consumption of at least one hundred grams of coconut per person.127 In addition, Dunning’s glib answer does not explain why the AEC failed to remove the Bikinians after the ERDA discovered high levels of radiation in the food and water on the atoll in 1975. Because of the studies conducted on the Bikinians between 1970 and 1975, the scientists knew that the body burdens of plutonium were steadily increasing. In addition, earlier studies conducted by Conard and the BNL researchers on the people of Rongelap clearly showed that the body burdens of cesium-137 and strontium-90 in that population increased once they were returned to their contaminated atoll. Given the available data from these studies,128 it is difficult to avoid the conclusion that Dr. Conard and his team utilized the Bikinians as research subjects during the period between 1970 and 1978.

Indeed, the BNL’s studies of both the Bikinians and the Rongelapese fit neatly into one of the “common and recurring” categories of human radiation experiments later identified by the Department of Energy. According to the department’s own definition, “All radionuclide metabolism studies in human subjects were considered as human radiation experiments. These tests involved the study or analysis of radioisotope uptake, retention, and excretion, and were done to learn more about the specific behavior of elements in the body.”129

Given the alarming levels of radionuclides in the bodies of the Bikinians, the Department of Interior finally decided to move them off their contaminated atoll. On 11 August 1978, Undersecretary James Joseph traveled to Bikini and offered to move the islanders back to Kili. Since the United States considered itself “generally responsible for the well-being of the Bikini people and their descendants,” it was willing to “arrange their relocation, permanently, in the most satisfactory manner possible.” Recognizing that the housing and other facilities on Kili were inadequate, the Americans were prepared to “undertake a program for the permanent rehabilitation” of the island. A new dispensary, school, and houses would be built on Kili and improvements would be made to the existing church and assembly hall. In addition, the United States agreed to give the Bikinians a onetime relocation allowance of $100.72, to be paid to the head of each family now on Bikini Island. However, the Americans wanted the islanders to understand that this sum was “not intended to constitute compensation, in whole or in part, for any damage the Bikini Island residents may be found to have sustained.” If the relocated Bikinians wanted to return to their home atoll, the Trust Territory government would arrange for brief visits from “time to time”; nevertheless, it was important for them to realize that Bikini Island “would not be fit for human habitation for decades to come.”130

According to islander Emso Leviticus, “We were devastated when we had to evacuate Bikini in 1978. We were crying; it was a hopeless feeling.”131 By late August, most of the 139 residents on Bikini Island returned to Kili but some moved to other islands, such as Ejit (part of the Majuro Atoll). As Charles Bussell, a Food Services Officer, reported, conditions on Kili remained extremely difficult:

The island is inhospitable by comparison to others, i.e. there is no lagoon, it is not capable at this time of producing sufficient food supplies to meet the needs of the persons living there regardless of income. There is no airstrip or dock for regularly scheduled shipping. From late November through March heavy seas and surf make supply logistics exceedingly hazardous. The people as a group are virtual prisoners of their environment. The sea is shark infested making traditional fishing—usually lagoon oriented—nearly impossible. Over the years the population has become totally dependent on USDA donated foods.132

In Bussell’s view, the Bikinians had become too reliant on Washington for food, a dependency fostered by their lawyers, and their “activities in the courts.”133 Nevertheless, the pressure employed by the Bikinians’ legal counsel was effective in helping them win additional financial aid from the Americans. In recognition of the hardships faced by the islanders, the US government passed Public Law 95348 in 1978, adding $3 million to the Bikinians’ trust fund.134 As well, the US Congress provided a $1.4 million ex gratia payment to the people of Bikini by Public Law 96-126.135

After the Bikinians were moved to Kili, Jonathan Weisgall, their legal counsel since 1975, filed a lawsuit in the US District Court in Hawai‘i demanding that the Americans conduct a full scientific survey of Bikini (and other atolls in the Northern Marshalls) to be completed “no later than December 31 of 1978.”136 In response to this pressure, the United States signed a memorandum of agreement promising to complete the survey using “the latest and most effective technology, including aerial radiation surveying.”137 As a result, the islanders dropped the lawsuit and the survey of Bikini was completed by the end of 1978.138 Unfortunately, this survey concluded that Bikini Island was so contaminated that it would be off-limits for sixty to eighty years and Eneu Island for twenty to twentyfive years.139

Ironically, the people of Bikini regained legal control of their contaminated atoll after being moved back to Kili. On 24 January 1979, the new high commissioner, Adrian Winkel, executed a quitclaim deed granting the Bikinians the legal right to their home atoll (as well as Kili Island and parts of Jaluit Atoll). According to this document, “all rights, title and interest of the Government of the Trust Territory of the Pacific Islands including use rights” were released “unto the people of Bikini.”140

This quitclaim deed put the Bikinians in a curious position. They regained legal control of their home atoll, but due to the high levels of radiation, they were not able to live there. Dissatisfied with their situation, the islanders asked their legal counsel to put additional pressure on Jimmy Carter’s administration. As their lawyer, Jonathan Weisgall, explained in his correspondence with the Department of the Interior, the islanders had both immediate and long-term goals. In the short term, they requested an independent (non-US government) scientific review and assessment of the radiological survey, with emphasis on the conditions of Bikini and Eneu Islands. By this time, they had “lost all trust in US government scientists.” In the longer term, the islanders had four main objectives: continued monitoring and cleanup of Bikini; eventual resettlement on the atoll; future medical care; and additional monetary compensation. From the islanders’ perspective, the United States bore direct responsibility and liability for their short-and long-term injuries, losses, and needs.141

The Bikinians also made other demands. In 1980, the Bikini Council requested that representatives from the Department of Energy come to Kili and participate in a Dose Assessment Conference (as the Americans had done at Enewetak in 1979).142 When the Americans arrived at this conference on October 8, they were greeted by protest signs that proclaimed “Welcome to Kili, Our Temporary Home” and “We wish no other home than Bikini.”143 A number of US representatives from the Departments of Energy and Interior attended this two-day meeting, accompanied by their legal counsel and scientists from the Lawrence Livermore Laboratory and the Pacific Northwest Laboratory. Leaders from the Marshallese government, the Bikini Council, their lawyers, and numerous people from the Kili community were also in attendance.144 During the conference, the US delegation presented the Bikinians with information in a booklet prepared by the DOE entitled “The Meaning of Radiation at Bikini Atoll.” According to this booklet, and the accompanying slide show, Bikini Island was still off-limits but Eneu might be habitable if the people followed proper guidelines, such as limiting their diet to 50 percent or less local food and agreeing to subject themselves to examinations by the Department of Energy.145

Perhaps not surprisingly, the Bikinians were not enthusiastic about this proposal. Given the recent official statements regarding the serious contamination on Eneu, Marshallese Senator Henchi Balos wanted to know why the Department of Energy was now suggesting that the Bikinians return to the island. Other islanders also asked questions. How much radiation already existed in their bodies due to the US testing program? What were the results of the examinations (whole-body counts and urine tests) done by the AEC in the 1970s? What would happen to them if they returned to Eneu? How contaminated was the island and what were the risks to their health? What if their children ate more food on the island than they were supposed to? If the island was safe, why was the DOE suggesting that they only eat some of the local food?146

In response, the DOE representatives provided answers that were not reassuring. Based on the studies of the Bikinians in the 1970s, the DOE had records regarding the amount of cesium-137 in the islanders’ bodies but these records were kept in the United States.147 Of those islanders who had radionuclides in their bodies, there was a “small chance” that some would die from cancer in the future. For those Bikinians who chose to return to Eneu, these health risks might increase, especially if they didn’t follow the guidelines and chose to eat only local food on Eneu. Even if the Bikinians did not eat any food grown on the island, there were no guarantees regarding their health. As Dr. Bill Bair of the Pacific Northwest Laboratory explained, “It’s never 100 percent safe to live anywhere. On Eneu, even if you do not eat any food grown on the island, you still will inhale radioactive material from the dust you breathe.”148

Given the nature of the information provided by the DOE at the conference, it is understandable that the Bikinians felt uneasy about returning to Eneu. Many were suspicious about the Department of Energy’s motivations. They wondered why the DOE wanted to move them back to the contaminated island and then conduct examinations of their bodies.149 Others highlighted their general lack of trust of the United States. One of the elder Bikinians put it this way:

I compare today’s meeting to the meeting we had when we were asked to leave Bikini originally. We were told by a person representing a country of great power to leave so testing could be done. We were afraid we would die if we didn’t leave. We were told we would be taken care of and watched over…. We went to Rongerik and were poisoned by fish…. We ended up here on Kili and were told we would be here until Bikini was safe and we would be told to return…. We are not happy here…. You brought us this book[let], I throw it down.150

Distrustful of the United States, the Bikinians decided that they wanted independent scientists to review the situation on Eneu before they made any decisions about returning. They also queried the Americans about compensation for the environmental damage caused by the nuclear testing program. Some asked about compensation for the destruction of several of their islands. As one Bikinian put it: “I wonder, since the bombs destroyed three islands, and they now no longer exist, do you plan to pay for those islands?”151

In reply, Gordon Law, the deputy assistant for the Department of Interior, contended that compensation was not “an Interior … legislative or moral obligation” for the United States.152 In his opinion, “Historically money ruins societies, it does no good.”153 Nevertheless, near the end of the conference, Law presented the Bikinians with $100 “as a small token,” in the hopes that it would “cause people to remember that a new era for the people of Bikini started here.”154

After the conference on Kili, representatives for the displaced islanders continued to present the Americans with requests. During a meeting with representatives from the Department of Interior, Senator Balos of the newly formed Republic of the Marshall Islands government repeated the Bikinians’ desire for independent scientists to review the environmental situation on their home atoll.155 In several telegrams to the high commissioner, Balos also emphasized the ongoing food shortages and transportation difficulties faced by the Bikinians living on Kili and Ejit.156 As the senator explained, “We did not voluntarily leave Bikini to come to Ejit. It was the US government who made us leave our beautiful shores and lands in Bikini atoll and brought us to a stranger’s lands on Ejit [in 1978]. Why doesn’t the US government live up to its obligations and responsibilities toward Bikinians? Is it because there are only hundred people out here, who gives a damn? If that’s so, take us back to Bikini atoll where we belong. We’d rather die on Bikini than be suffered [sic].”157

In early 1981, the Bikinians’ legal counsel sent a letter to the high commissioner outlining the islanders’ major grievances against the Americans: their removals from Bikini in 1946 and 1978, their suffering and hardship since 1946, the destruction of certain islands in their atoll, and various breaches of fiduciary responsibilities by the US government.158 Based on these complaints, the Bikini Council instructed Jonathan Weisgall to file a class action suit against the United States. By this time, the council was persuaded that litigation was the most effective way to force Washington to provide them with the monetary compensation they deserved. Their lawsuit sought compensation under the Fifth Amendment of the United States Constitution for the taking of their atoll (in 1946 and 1978).159 They also sought redress for the American government’s “repeated and continuing breaches of fiduciary duties” which had resulted in “severe physical, emotional, and financial injuries.” In total, the Bikinians demanded that the US government pay compensation not less than $450,000,000.160

The plaintiffs named in the petition were all members of the Bikini Council, but the suit was filed on behalf of all living persons who were members of the Bikini community prior to the 1946 evacuation and their descendants. At the time, over 990 members of the Bikini community—most lived on Kili and some on Ejit—were considered part of this case. According to their legal counsel, the people of Bikini chose a class action approach because it permitted “numerous injured persons to prosecute their common claims jointly in a single forum” and thus avoided unnecessary duplication.161 When a reporter from the Marshall Islands Journal interviewed Weisgall, the lawyer drew parallels between the Bikinians’ lawsuit and cases fought by Native Americans in the United States.162

Although the Bikinians’ lawsuit was unsuccessful, the pressure brought by the islanders did have an impact on the US Congress. In 1982, Congress voted in favor of a trust fund for the Bikinians under US Public Law 97-257; according to the terms of this legislation, entitled “The Resettlement Trust Fund for the People of Bikini,” the islanders were granted $20 million.163 Later, the US government passed additional legislation, Public Law 100-446, providing $90 million for the cleanup of Bikini and Eneu Islands of the Bikini Atoll.164

While this legislation was being considered by the US Congress, representatives from the Republic of the Marshall Islands and the United States were engaged in negotiations regarding the Compact of Free Association. In September 1983, a majority of Marshall Islanders (58 percent) voted in favor of this agreement with the United States. Under the compact, the Americans were granted full authority for all defense matters in the Marshall Islands, including the right to use Kwajalein Atoll as a missile testing base. In return, the Marshallese were given self-government and additional financial assistance from the United States. The Bikinians, however, were not party to the negotiations that led to the compact or the related Section 177 agreement,165 and 79 percent of them voted against it.166 At the time, the Bikinians realized that the amount of money offered by Washington would not provide sufficient compensation for the extensive health and environmental damages caused by the nuclear testing program.

Following approval of the compact in 1986, the United States created a fund that disbursed money to the four Marshallese communities whose atolls were most affected by nuclear tests (Bikini, Enewetak, Rongelap, and Utirik). From this fund, the Bikinians received a $75 million trust, with a yearly disbursement of $5 million over 15 years.167 As a condition of this trust fund, however, the Bikinians—like other islanders—were required to terminate any pending legal cases against the United States related to nuclear testing.168

Although the Bikinians could no longer file lawsuits in the United States, they continued to draw international attention to the problems caused by the nuclear testing program. In 1988, a delegation from the Marshall Islands gave testimony

Figure 2.5.

Senator Henchi Balos, legal counsel Jonathan Weisgall, Mayor Tomaki Juda, and liaison Jack Niedenthal testifying at the UN in 1988.

Credit: Jack Niedenthal.

at the United Nations regarding the ongoing challenges involved in the cleanup and resettlement of Bikini Atoll.

That same year, the Bikinians sent letters to various Americans inviting them to “Bikini Day,” an annual event held on Kili to commemorate their displacement. As the invitations explained, the celebration on Kili marked “42 years of exile from our homelands … and ten years since we discovered the true extent of the damage done to our islands by the nuclear tests.”169 On March 11, the islanders and their guests enjoyed music, dancing, food, and speeches by prominent Bikinians. Iroij Kotak Loeak said that he shared the sorrow felt by the Bikinians who lived on Kili. “There’s no place better than home,” he stated. Nitijela Speaker Kessai Note thanked all of the Bikini leaders who had tried to make life better on Kili. As he put it, “The advances of the Bikini people have come from the people themselves.” Senator Henchi Balos emphasized the community’s wish that the US Congress continue to provide necessary funding for the cleanup and rehabilitation of Bikini. As a sign carried by a young Bikinian declared, however, “There are miles to go and promises to keep.”170

In keeping with one of these promises, the United States supported the creation of the Nuclear Claims Tribunal (NCT) on Majuro in 1988. Once the tribunal was established, the Marshallese affected by the nuclear tests began to make individual claims. Mr. Leviticus, for example, filed a personal injury claim after his son, Dial, died of a “very aggressive lymphoma.” Dial was one of the young children who returned to Bikini Island with his family in the 1970s. During the two years and three months that he lived on the contaminated island, he was exposed to an excessive amount of radiation. After reviewing the evidence presented by experts in this case, the NCT concluded that Dial’s family should be given an award since there was a direct connection between his exposure to radiation on Bikini Island and the onset of the lymphoma that killed him prematurely at age eleven.171

In addition to individual claims, the People of Bikini filed a class action claim with the NCT in 1993 seeking damages resulting from the consequences of the US nuclear testing program. Based on this claim, the tribunal held several hearings, reviewed thousands of pages of documents and reports, listened to arguments from expert witnesses and lawyers, and heard testimony from the Bikinians themselves. During the deliberations for this case, the defendants went to great lengths to minimize the problems caused by the American program.172 Eventually, though, the NCT was more convinced by the evidence provided by the witnesses speaking on behalf of the islanders. In 2001, the Tribunal concluded that the Bikinians should be granted a total award of $563,315,500: $278,000,000 in compensation for loss and use of their atoll; $251,500,000 for the cleanup and restoration of Bikini;173 and $33,814,500 for the hardships suffered during their long exile. The NCT concluded:

The process has been a long and difficult one as the Tribunal has grappled with many issues in need of resolution in the decision process. However, none of what has transpired before the Tribunal can begin to compare with the stark reality that the People of Bikini have remained in exile for some 55 years now. Although the Tribunal has determined that the people of Bikini have suffered loss and injury to person and property, nothing can compensate for that simple fact and all of the attendant intangible damage, loss, and hardship suffered by the Bikini community over the years. In this respect, the Tribunal hopes this award will help bring closure to this tragic legacy, and allow the Bikini community to move forward empowered to make their own future.174

In the end, however, the United States did not adequately fund the NCT and the Bikinians (like the Enewetakese) only received a small fraction of the award granted by the tribunal. Although small initial payments were made to the Bikinians (totaling $2,279,179.83), they represented less than one-half of one percent of the total award. Since Washington failed to provide any further payments, the Bikinians filed a case with the US Court of Federal Claims. When that case was dismissed on appeal, the Bikinians sent a petition to the US Supreme Court, but it was denied on the grounds that the Marshall Islanders gave up their right to pursue claims in the United States once they signed the Compact of Free Association.175

Despite the Supreme Court’s negative decision, the Bikinians continued to seek justice and their legal counsel filed another lawsuit against the American government in the US Court of Federal Claims in April 2006. This suit sought compensation under the Fifth Amendment of the US Constitution for the Americans’ failure and refusal to adequately fund the 2001 order of the Nuclear Claims Tribunal. More specifically, the Bikinians requested $561,036,320, the amount still owed by the United States as a result of the NCT order, for “past and future loss of use of Bikini Atoll, restoration costs for a radiological cleanup of the atoll, and hardships for property and consequential damages” of the nuclear testing program.176 After several amendments and appeals, the Bikinians’ petition to have this case heard in the US Supreme Court was denied in 2010.177

By conducting twenty-three nuclear explosions on the Bikini Atoll between 1946 and 1958, the United States was able to develop powerful atomic and thermonuclear bombs and, at the same time, study the effects of radiation on human beings. While these military and human experiments bolstered the American strategy of deterrence during the Cold War, they caused serious health conditions in the Bikinians and widespread ecological degradation. As a result of the nuclear explosions, three islands of Bikini were annihilated and the remainder of the atoll was contaminated with radionuclides dangerous to human health, such as cesium-137, strontium-90, and plutonium.178 Yet, more than twenty-five years after the end of the conflict with the Soviet Union, the Bikinians remain displaced from their homeland and they are still seeking compensation for the health and environmental damage caused by the nuclear tests. Even though the Nuclear Claims Tribunal, a body approved by the United States, decided in favor of the case presented by the Bikinians, Washington has failed to pay the total award granted for the damages caused by the US testing program. Consequently, the people of Bikini must continue to petition the US Congress to live up to its fiduciary obligations. Unfortunately, however, as Jack Niedenthal, their official liaison, concludes, “This is expected to take many years and it is uncertain if the United States will honor their claim.”179

Notes

1.
Paul Boyer, By the Bomb’s Early Light: American Thought and Culture at the Dawn of the Atomic Age (New York: Pantheon Books, 1985), 83.

2.
For discussions of the containment strategy and the emerging Cold War tensions in the early postwar period, see
John Lewis Gaddis, Strategies of Containment: A Critical Appraisal of Postwar American National Security Policy (Oxford: Oxford University Press, 1982), 25–88
; and
Martin McCauley, The Origins of the Cold War, 1941–1949 (London: Pearson Longman, 2008).

3.
As the AEC explained, “The Commission felt that tests should be held overseas until it could be established more definitely that continental detonations would not endanger the public health and safety.” Quoted in
Jonathan Weisgall, “The Nuclear Nomads of Bikini,” Foreign Policy 39 (Summer 1980): 76.

4.
Quoted in
Jonathan Weisgall, Operation Crossroads: The Atomic Tests at Bikini Atoll (Annapolis, MD: Naval Institute Press, 1994), 31.

6.
Lore Kessibiki, magistrate of Kili, to Edward Johnston, high commissioner, Trust Territory of the Pacific Islands, letter, 14 December 1969, Roll 337, Box 29, RG 200, NAGC, TTPI, NAII.

9.
Weisgall, Operation Crossroads, 114. This chapter builds on the excellent research published by Weisgall, legal counsel for the Bikinians; Robert Kiste, an anthropologist who worked in the Marshalls; and Jack Niedenthal, liaison for the people of Bikini. See Weisgall, “The Nuclear Nomads,” and Operation Crossroads;
Kiste, The Bikinians: A Study in Forced Migration, Kiste and Ogan Social Change Series in Anthropology (Menlo Park, CA: Cummings, 1974)
; and
Niedenthal, For the Good of Mankind: A History of the People of Bikini and Their Island (Majuro, Marshall Islands: Micronitor, 2001).

10.
Jack Tobin, Preliminary Anthropologist’s Report: Bikini Atoll Survey 1967, Department of Energy Historian’s Office Archives, http://www.hss.energy.gov/HealthSafety/IHSmarshall/collection/ihp/chron/B32.PDF
; Kiste, The Bikinians, 31.

12.
Tobin, Preliminary Anthropologist’s Report: Bikini Atoll Survey 1967. See also People of Bikini vs. United States of America,
Petition in the Nature of a Class Action for Just Compensation for Unlawful Takings of Property and for Damages for Breaches of Fiduciary Duties, 16 March 1981, Roll 337, Box 29, RG 200, NAGC, TTPI, NAII.
Like other communities in the Marshalls, the Bikinians had developed a three-tier social system. The iroij were chiefs who maintained authority over the clans and the land. The alabs were managers who ensured, on behalf of the iroij, that the land was properly maintained and that everyone was provided for according to custom. The ri-jerbal, the majority, cultivated the land and provided food and labor to the iroij. See
Holly Barker, Bravo for the Marshallese: Regaining Control in a Post-Nuclear, Post-Colonial World, Case Studies in Contemporary Social Issues Series (Belmont, CA: Thomson Wadsworth, 2004), 10.

13.
Use and Occupancy Agreement for Land in the Trust Territory of the Pacific Islands under the Administrative Responsibility of the Department of the Interior, 15 April 1946, Roll 337, Box 29, RG 200, NAGC, TTPI, NAII.

14.
People of Bikini vs. United States of America, 16 March 1981, NAII.

16.
Jack Niedenthal, “Bikini Atoll: A Short History of the People of Bikini Atoll,” www.bikiniatoll.com/history/htmlreference
. See also
People of Bikini vs. United States of America, 16 March 1981, NAII
; Weisgall, Operation Crossroads, 117–120.

17.
Peter Hayes, Lyuba Zarsky, and Walden Bello, American Lake: Nuclear Peril in the Pacific (Ringwood, Australia: Penguin Books, 1986), 69
;
Richard Hewlett and Oscar Henderson, The New World 1939–1946 (University Park: Pennsylvania State University Press, 1962), 581–582.

19.

Weisgall, Operation Crossroads, 120–121 (and endnote 20, p. 342). Apparently, pigs have skin like humans and goats have similar respiratory systems.

20.
Julianne Walsh, Etto nan Raan Kein: A Marshall Islands History (Honolulu, HI: Bess Press, 2012), 290.

21.

Walsh, Etto nan Raan Kein: A Marshall Islands History, 290; Weisgall, Operation Crossroads, 120, 199, 220, 356 (endnote 28). Most of the animals were exposed during the first test, Able. Of the 656 animals that died in the blast, there were 23 goats, 11 pigs, 2 guinea pigs, 619 rats, and 1 mouse. By the middle of November 1946, 1,953 of the animals had died.

24.
Radiation levels near the point of the blast reached a lethal 730 roentgens within the first twenty-four hours. See
Mark Merlin and Ricardo Gonzalez, “Environmental Impacts of Nuclear Testing in Remote Oceania, 1940–1996,” in Environmental Histories of the Cold War, ed. J. R. McNeill and Corrina Unger (New York: Cambridge University Press, 2010), 181–182.

25.
“Move of People of Bikini Atoll to Kili Island,” prepared for the high commissioner, Trust Territory of the Pacific Islands, background memo, December 1979, Roll 156, Box 13, RG 200, NAGC, TTPI, NAII.

27.
Hamlet Barry and James Licke, legal counsel for the displaced people of Bikini, to President Richard Nixon, letter, 4 May 1973, Roll 337, Box 29, RG 200, NAGC, TTPI, NAII.

28.
Leonard Mason, Rongerik Report, 24 January–8 February 1948, in From a Time of Starvation to a Time for Hope: The Relocation of the Bikini Marshallese, University of Hawai‘i at Mānoa (hereafter UHM).
According to Mason, the people got sick when they ate small fish caught near the island because they were “poisonous.” See also Kiste, The Bikinians, 85; Weisgall, Operation Crossroads, 312.

30.
Barry and Licke to Nixon, 4 May 1973, NAII.

34.

According to Kiste, some atolls were not visited for periods of six or more months, schedules were uncertain, and no provision was made to ensure that ships would carry the desired quantities and varieties of trade goods when they did call. See Kiste, The Bikinians, 109.

35.
Barry and Licke to Nixon, 4 May 1973, NAII.

36.
Release of Rights to Bikini Atoll, 27 April 1951, Roll 337, Box 29, RG 200, NAGC, TTPI, NAII.

37.
Release of Rights to Bikini Atoll, 27 April 1951, NAII.
See also
People of Bikini vs. United States of America, 16 March 1981, NAII.

38.
The Soviet Union tested its first thermonuclear device, RDS-6 (with a yield of 400 kilotons), on 12 August 1953 at the Semipalatinsk site. See
Pavel Podvig, ed. Russian Strategic Nuclear Forces (Cambridge, MA: MIT Press, 2001), 463.

39.

US Department of Energy, United States Nuclear Tests: July 1945 Through September 1992, DOE/NV-209 (Rev. 14) (December 1994), 3. The US tests took place between 1 March 1954 and 4 May 1954.

40.
Report Prepared by the Defense Nuclear Agency for the Department of Defense, 1 April 1982, DNA 6035F, Castle Series 1954, NAII.
According to this report, the fireball was three miles in diameter and the crater in the atoll one mile across and two hundred feet deep. For the geological impacts of the other nuclear tests in the Castle series, see Merlin and Gonzalez, “Environmental Impacts of Nuclear Testing,” 175, 177.

41.
Petition to the United Nations from the Marshallese People, 20 April 1954, 711.5611/5654, Department of State Record Group (hereafter DSRG) 59, National Archives (hereafter NA), Washington.

42.
Petition to the UN, 20 April 1954, NA.
As Robert Kiste explained during expert testimony before the Nuclear Claims Tribunal, “It is probably no exaggeration to suggest that short of loss of life itself, the loss of their ancestral homeland represented the worst calamity imaginable for the Bikinians.” See
Memorandum of Decision and Order, In the Matter of the People of Bikini et al., Before the Nuclear Claims Tribunal, Republic of the Marshall Islands (NCT No. 23-04134), 5 March 2001, 8, http://www.nuclearclaimstribunal.com/bikinifin.htm.

43.
Petition to the UN, 20 April 1954, NA.

44.
State Department to the US Delegation at the UN, telegram, 6 May 1954, 711.5611/5654, NA.

45.
State Department to American Embassies in Tokyo and New Delhi, telegram, 9 January 1956, DSRG 59, 711.5611/1-956, NA, Washington
;
President’s Special Committee on Disarmament Problems, minutes, 9 January 1956, Series I, WHOSAD, DDEL, Abilene.
See also
“Review of USIA Guidance on Forthcoming Public Announcements of US Proving Ground Weapons Tests Series,” memorandum, 12 January 1956, WHO, NSC StaffPapers, OCB Central File Series, DDEL, Abilene.

46.
Petition from the Marshallese Congress, Seventeenth Session, Agenda Item 4, UN Trusteeship Council, 28 March 1956, FO371/123137, Public Records Office (hereafter PRO), Kew, England
; See also
State Department to the American Delegation at the UN in New York, telegram, 19 March 1956, DSRG 59, 711.5611/3-2056, NA.

47.
Michael Harris, The Atomic Times: My H-Bomb Year at the Pacific Proving Ground (New York: Ballantine Books, 2005), 258.

51.
Verbatim notes of meeting held on Kili Island for Delmas Nucker, high commissioner, Trust Territory of the Pacific Islands, 10 November 1956, Roll 337, Box 29, RG 200, NAGC, TTPI, NAII.

52.
Agreement in Principle Regarding the Use of Bikini Atoll, 22 November 1956, Roll 337, Box 29, RG 200, NAGC, TTPI, NAII.

53.
Barry and Licke to Nixon, 4 May 1973, NAII.

55.
See
Martha Smith-Norris, “The Eisenhower Administration and the Nuclear Test Ban Talks, 1958–1960: Another Challenge to ‘Revisionism,’ ” in Diplomatic History 27 (September 2003): 503–541.

56.
Leonard Mason to Peter Coleman, district administrator, Marshall Islands, letter, 17 February 1964, Roll 337, Box 29, RG 200, NAGC, TTPI, NAII.

57.
Tobin visited Kili on 17 April 1968. See
Jack Tobin, Community Development Department, Majuro, to Distad Marshalls, memorandum, 25 April 1968, Reel 214, Hamilton Library Trust Territory Archives (hereafter HLTTA), UHM.
Tobin predicted that this action might “take the form of a mass evacuation from the island, as threatened by alab Kilon last November.” Tobin had informed the Distad Marshalls about this threat in an earlier memo dated 28 November 1967. Apparently, the Kili people had heard about the “Ujilan [sic] ‘ship in’ incident, and thought it an effective means of protest.”

58.
The gamma-ray radioactivity included cesium-137, cobalt-60, and antimony-125. See
Philip Gustafson, Fallout Studies Branch, Division of Biology and Medicine, Atomic Energy Commission, Brief Summary of the Radiological Status of the Bikini Atoll, May 1968, DOE Historian’s Office Archives.

59.
Gustafson, Brief Summary, May 1968, DOE Historian’s Office Archives.

60.
 
Robert Conard et al., Report of the Ad Hoc Committee to Evaluate the Radiological Hazards of Resettlement of the Bikini Atoll, to the Atomic Energy Commission, 8 July 1968, 4,
and
John Totter, director, Division of Biology and Medicine, AEC, to Glenn Seaborg, chairman, AEC et al., letter, 8 July 1968, DOE Historian’s Office Archives.

61.
See
Jack Tobin to Distad Marshalls, memorandum, 17 July 1968, Reel 214, HLTTA, UHM.

62.
Office of the White House Press Secretary, press release, 12 August 1968, Roll 339, Box 29, RG 200, NAGC, TTPI, NAII.

65.
The cleanup operation on Bikini, involving the removal of “test-related debris, unusable structures, and scrub vegetation,” took from February to September 1969. This cleanup employed seventy-four men, eleven of whom were “Bikini natives.” See
L. M. Mustin, vice admiral, United States Navy, Defense Atomic Support Agency, to the secretaries of defense and interior and the chairman of the Atomic Energy Commission, Second Status Report: Cleanup of Bikini Atoll, 1 July 1969, Roll 337, Box 29, RG 200, NAGC, TTPI, NAII.

66.
Bikini, Eniwetok and Kwajalein, US position book, 37th Session Trusteeship Council, 26 May–15 June 1970, Box 13, Roll 156, RG 200, NAGC, TTPI, NAII.
See also Niedenthal, For the Good of Mankind, 10.

67.
Bikini, Eniwetok and Kwajalein, 26 May–15 June 1970, NAII.

68.
Newsreel footage of Dr. Conard, in Thomas Maier’s documentary,
“Fallout: Brookhaven National Lab in the Pacific,” chapter 6, Newsday, August 2009, http://www.youtube.com/watch?v.

69.
Eight months after the exposed Rongelapese (and a control group) were returned to their contaminated island in 1957, their body burdens of cesium-137 increased 140-fold while the levels of strontium-90 rose 20-fold. See
Conard, Medical Status of Rongelap People: Five Years after Exposure to Fallout Radiation, 1 June 1959, Special Assistant to the Secretary of Energy and Outer Space, Records Relating to Atomic Energy Matters, 1944–1963 (hereafter cited as SASEOS, RAEM), DSRG 59, NAII, 3–4.

70.
See, for example,
Conard et al., Medical Survey of the People of Rongelap and Utirik Islands Thirteen, Fourteen, and Fifteen Years after Exposure to Fallout Radiation (March 1967, March 1968, and March 1969), Roll 328, Box 28, RG 200, NAGC, TTPI, NAII, 45.

71.
This is the language that Conard used to explain the research value of the earlier studies on Rongelap. See
Conard et al., Medical Survey of Rongelap People Five and Six Years after Exposure to Fallout, September 1960, NAII, 58.

72.
Edward Held, Radiological Survey of Animals, Soils and Groundwater at Bikini Atoll, 1969–1970, AEC, Roll 339, Box 29, RG 200, NAGC, TTPI, NAII, 8–9, 13.
In this report, Held explained that the concentration of these radionuclides in some animals (such as the coconut crab and the curlew bird) had a “maximum value” (p. 8).

73.

Similarly, marine organisms would ingest radionuclides by eating other marine organisms or by ingesting sediments in the water.

74.
Held, Radiological Survey, 1969–1970, NAII, 15.

75.
Similar urine tests had been conducted on the people of Bikini and Rongelap in 1967 and 1968. See
Conard et al., Medical Survey of the People of Rongelap and Utirik, 1967, 1968, 1969, NAII, 39.

76.
 
Conard et al., Medical Survey of the People of Rongelap and Utirik, 1967, 1968, and 1969, NAII, 39–40.

77.
Conard, Medical Department, BNL (under contract to the United States Department of Energy), Review of Medical Findings in a Marshallese Population Twenty-Six Years after Accidental Exposure to Radioactive Fallout, January 1980, Roll 328, Box 28, RG 200, NAGC, TTPI, NAII, 84.

78.
Jonathan Weisgall, legal counsel for the people of Bikini, to James Joseph, undersecretary of the Interior, Department of the Interior, letter, 12 June 1979, Roll 337, Box 29, RG 200, NAGC, TTPI, NAII.

79.
Loma Linda University School of Health, Marshall Islands: A Health Care Proposal, submitted to the Department of the Interior, 3 December 1980, Roll 337, Box 29, RG 200, NAGC, TTPI, NAII.

80.

Pero Joel, interview by Niedenthal, 1989, in For the Good of Mankind, 71–72.

81.
Kessibuki to Johnston, letter, 14 December 1969, NAII.

82.
Kessibuki to Johnston, 14 December 1969, NAII.
Kessibuki also requested that the “Trust Territory send us counsel to help us in the legalities of this matter as we are unfamiliar with the correct procedure to take.”

83.
Jack Tobin to Edward Johnston, high commissioner, letter, 5 March 1970, Reel 214, HLTTA, UHM.

84.
Tobin to Johnston, 5 March 1970, HLTTA, UHM.

85.
Edward Johnston, high commissioner, Trust Territory of the Pacific Islands, to Elizabeth Farrington, director, Office of the Territories, United States Department of Interior, position paper, 22 April 1970, Roll 337, Box 29, RG 200, NAGC, TTPI, NAII.
For similar arguments, see
“Annex E,” Kessibuki, 26 May–15 June 1970, NAII.

86.
People of Bikini vs. United States of America, 16 March 1981, NAII.
See also
Agreement Acknowledging the Return of the Bikini Atoll to the Trust Territory of the Pacific Islands Subject to Certain Retention Areas and Rights of the United States of America, 17 March 1970, Roll 337, Box 29, RG 200, NAGC, TTPI, NAII.
Under this agreement, the US maintained its right to use Ourukaeen, Eninman, and Eneu islands.

87.
Kili Council to Edward Johnston, high commissioner of the trust territory, letter, 21 May 1970, Roll 337, Box 29, RG 200, NAGC, TTPI, NAII.
As a sign of protest, the Kili Council boycotted the AEC’s survey by refusing to allow any Bikinian workers to help Dr. Held gather specimens from the contaminated atoll. See
Jack Tobin to deputy high commissioner, letter, 27 May 1970, Roll 339, Box 29, RG 200, NAGC, TTPI, NAII.

88.
Robert Hefner, attorney general, Summary of Meeting with the Kili Council at Majuro, 4 March 1971, Roll 337, Box 29, RG 200, NAGC, TTPI, NAII.
See also
Barry and Licke to Nixon, 4 May 1973, NAII.

89.
Hefner, Summary of Meeting, 4 March 1971, NAII.

90.
Hefner, Recommendations re: Summary of Meeting, 4 March 1971, NAII.

91.
Amendment to the Agreement in Principle Regarding the Use of Bikini Atoll, 6 March 1971, signed by Magistrate Lore Kessibuki (and four other members of the Bikini Council) and High Commissioner Edward Johnston, Roll 337, Box 29, RG 200, NAGC, TTPI, NAII.

92.
Barry and Licke to Nixon, 4 May 1973, NAII.

93.
Petition and Statement of Justification for an Ex Gratia Payment of Three Million Dollars to Edward Johnston, High Commissioner, 10 April 1974, Roll 337, Box 29, RG 200, NAGC, TTPI, NAII.
Both documents, which were signed by Magistrate Lore Kessibuki, Scribe Nathan Note, Councilman Moses Lewaj, and Congressman Ataji Balos, made reference to the US ex gratia payment of $1,020,000 to the people of Ujelang in 1969.

94.
Jack Tobin to Edward Johnston, High Commissioner, letter, 28 June 1973, Roll 339, Box 29, RG 200, NAGC, TTPI, NAII.

95.
See, for example,
Hamlet Barry, MLSC attorney for the Bikinians, to Stanley Carpenter, Department of the Interior, letter, 14 March 1974, Roll 339, Box 29, RG 200, NAGC, TTPI, NAII.
See also
Hamlet Barry to Oscar deBrum, district administrator, Majuro, 5 April 1974, Roll 339, Box 29, RG 200, NAGC, TTPI, NAII.

96.
District administrator, Marshall Islands, to high commissioner, Saipan, telegram, May 1974, Roll 339, Box 29, RG 200, NAGC, TTPI, NAII.

97.
Petition for an Ex Gratia Payment, 10 April 1974, NAII.

98.
Public Law 94-34, H.R. 5158, 94th Cong., (13 June 1975), Roll 337, Box 29, RG 200, NAGC, TTPI, NAII
; Jack Niedenthal, Bikini Liaison Office, “Current Trust Funds for the People of Bikini Atoll,” http://www.bikiniatoll.com/repar.html.

99.
Hill Williams, science editor, The Seattle Times, to Lloyd Meeds, House Office Building, Washington, DC, letter, 7 July 1969, Roll 339, Box 29, RG 200, NAGC, TTPI, NAII.

100.
Niedenthal, For the Good of Mankind, 10. See also two letters from
Lewis Glenn, district administrator’s representative on Bikini, to the district administrator, Marshall Islands, 13 June 1970 and 10 September 1971, Roll 337, Box 29, RG 200, NAGC, TTPI, NAII.

101.
Barry and Licke to Nixon, 4 May 1973, NAII.

102.
Niedenthal, For the Good of Mankind, 11. According to Conard, the three families moved to Bikini sometime in 1971. See
Conard, Review of Medical Findings in a Marshallese Population, January 1980, NAII, 84.

103.
Dr. Martin Biles, AEC, to Edward Johnston, high commissioner of the Trust Territory of the Pacific Islands, tele gram, April 1972, Roll 337, Box 29, RG 200, NAGC, TTPI, NAII.

104.
Barry and Licke to Nixon, 4 May 1973, NAII.

105.
Background on the Bikini Rehabilitation Project with Update, prepared for the high commissioner, Trust Territory of the Pacific Islands, December 1979, Roll 156, Box 13, RG 200, NAGC, TTPI, NAII.

106.

The US Nuclear Regulatory Commission defines a “whole-body counter” as “a device to identify and measure the radioactive material in the body of human beings and animals. It uses heavy shielding to keep out naturally existing background radiation and ultrasensitive radiation detectors and electronic counting equipment.” See http://www.nrc.gov/reading-rm/basic-ref/glossary/whole-body-counter.html.

107.
Conard, BNL, to Oscar deBrum, district administrator, Marshall Islands, letter, 9 January 1975, Roll 337, Box 29, RG 200, NAGC, TTPI, NAII.
See also Table, Marshall Island Urine Specimens: Bikini,
1974 Spring Survey, Roll 337, Box 29, RG 200, NAGC, TTPI, NAII.
This table includes urine analysis for eleven islanders who had been on the island for various periods of time, ranging from eight months to three years.

108.
People of Bikini vs. United States of America, 16 March 1981, NAII.

109.
Roger Morton, secretary of the interior, to James Schlesinger, secretary of defense, letter, 7 March 1975, Roll 337, Box 29, RG 200, NAGC, TTPI, NAII.

110.
William Clements, deputy secretary of defense, to James Schlesinger, secretary of defense, letter, 29 May 1975, Roll 337, Box 29, RG 200, NAGC, TTPI, NAII.
See also
Kent Frizzel, acting secretary of the interior, to James Schlesinger, secretary of defense, letter, 17 July 1975, Roll 337, Box 29, RG 200, NAGC, TTPI, NAII.

111.
 
People of Bikini vs. United States of America, 16 March 1981, NAII.
See also George Milner, acting director, Office of Territorial Affairs, Department of the Interior, to Adrian Winkel, high commissioner, Trust Territory of the Pacific Islands, letter and report,
Current Status of Bikini Resettlement Project and Related Aspects, 12 July 1977, Reel 334, HLTTA, UHM.

112.
ERDA Radiological Survey of Bikini and Eneu Islands, June 1975, Roll 337, Box 29, RG 200, NAGC, TTPI, NAII.
See also
ERDA Preliminary Report: Radiological Evaluation of Phase II Housing Construction on Bikini Atoll, 6 August 1975, Roll 337, Box 29, RG 200, NAGC, TTPI, NAII.

113.
James Joseph, undersecretary, Department of Interior, to Thomas P. O’Neill Jr., speaker, House of Representatives, letter, Washington, DC, 6 February 1979, Roll 156, Box 13, RG 200, NAGC, TTPI, NAII.

114.
In addition, the lawyers pointed out that the people living on Kili were suffering from hunger and “possible starvation.”
Summary Report of the Meeting between Fred Zeder, Director of Territorial Affairs and George Allen, Legal Counsel for Bikini People, and Ed King, Co-Counsel, Deputy Director, MLSC, 24 October 1975, Roll 339, Box 29, RG 200, NAGC, TTPI, NAII.

115.
Oscar deBrum, district administrator, Marshall Islands, to high commissioner, Trust Territory of the Pacific Islands, letter, 15 August 1975, Roll 337, Box 29, RG 200, NAGC, TTPI, NAII.

116.
Magistrate Tomaki Juda et al., Petition from the Kili/Bikini Council, to the Honorable Phillip Burton, US Congress, 19 July 1977, Reel 334, HLTTA, UHM.
See also
George Allen, legal counsel for the people of Bikini, to Phillip Burton, US Congress, letter, 19 July 1977, Reel 334, HLTTA, UHM.

117.
W. L. Robison, V. E. Noshkin, Lawrence Livermore Laboratory, “Plutonium Concentrations in Dietary and Inhalation Pathways at Bikini and New York,” 27 September 1976, http://www.hss.energy.gov/healthsafety/env_docs/200118.pdf, 15.reference

118.
Milner to Winkel, 12 July 1977, Reel 334, HLTTA, UHM.
See also
Weisgall to Joseph, 12 June 1979, NAII.

119.
Milner to Winkel, 12 July 1977, HLTTA, UHM.

120.
Konrad Kotrady, M.D., The Brookhaven Medical Program to Detect Radiation Effects in Marshallese People, 1 January 1977, Roll 323, Box 27, RG 200, NAGC, TTPI, NAII, 10.
Kotrady worked in the islands from June 1975 until August 1976.

122.
List of Names and Members of Families Residing at Bikini, 31 August 1977, Roll 337, Box 29, RG 200, NAGC, TTPI, NAII.

123.
Use of Eneu Island Instead of Bikini Island for Residential Purposes, prepared for the high commissioner, Adrian Winkel, Trust Territory of the Pacific Islands, 9 May 1978, Roll 156, Box 13, RG 200, NAGC, TTPI, NAII.

124.
Conard, Review of Medical Findings in a Marshallese Population, January 1980, NAII, 84.
See also
People of Bikini vs. United States of America, 16 March 1981, NAII.

125.
The People of Bikini, by and through the Kili/Ejit Local Government Council, Plaintiffs, v. the United States of America, Defendant, in the United States Court of Federal Claims (Case Prepared by Jonathan Weisgall), 11 April 2006, 10, http://www.bikiniatoll.com/2006%20Bikini%vs.%20US%20CFC.pdf.reference
See also Weisgall, “The Nuclear Nomads,” 89. For the total body doses of radiation from internal and external sources for the people who resided on Bikini between 1969 and 1978, see Conard, Table 7,
Review of Medical Findings in a Marshallese Population, January 1980, NAII, 120.
According to this table, there were seventeen adult males, sixteen adult females, and twelve children in the study group.

126.
Weisgall, Operation Crossroads, 315. Weisgall conducted an interview with Dunning on 8 June 1986. See also
People of Bikini vs. United States of America, 16 March 1981, NAII.

127.
W. L. Robison, Table 139, “Postulated Diet for the Returning Adult Enewetak Population,” Enewetak Radiological Survey: Dietary and Living Patterns, USAEC, Nevada Operations Office, Las Vegas, NVO-140, Vol. 1 (1973): 496.

128.
See, for example,
Conard, Medical Status of Rongelap People, 1 June 1959, NAII, 3–4.
See also
Conard et al., Medical Survey of the People of Rongelap and Utirik, 1967, 1968, and 1969, NAII, 48.

129.
US Department of Energy, Experiments List: Human Radiation Experiments Associated with the US DOE and Its Predecessors, Openness: Human Radiation Experiments: Road-map to the Project, July 1995 (Washington, DC), 6, http://www.hss.doe.gov/healthsafety/ohre/roadmap/experiments/index.html.

130.
Statement of Understanding on the Part of the Government of the United States and the Government of the Trust Territory of the Pacific Islands Concerning the Move of the People of Bikini Island, 16 August 1978, Roll 337, Box 29, RG 200, NAGC, TTPI, NAII.

131.
Quoted in
GiffJohnson, “Bikinian Return a Sad Occasion for Elders,” The Marshall Islands Journal (February 1997), http://www.bikiniatoll.com/news.html.

132.
Charles Bussell, food ser vices officer, Report of Field Trip Activities: Marshall Islands, 30 November–4 December 1976, Roll 337, Box 29, RG 200, NAGC, TTPI, NAII.
Bussell also commented on the condition of the school on Kili (attended by 117 children): “The interior consisted of a bare and somewhat damp concrete floor, no desks or chairs or tables. One section of Masonite/pointed chalk board was in evidence. No books, reference materials or other learning aids were apparent.”

133.
Bussell, Report of Field Trip Activities: Marshall Islands, 30 November–4 December 1976, NAII.
Bussell specifically mentioned George Allen, who became the Bikinians’ lawyer when he was a staffattorney for the MLSC. Allen’s representation of the islanders was essentially on a pro bono basis. For his expenses (especially travel), he was compensated $10,000 a year. See
George Allen to Patricia Krause, legal counsel, Subcommittee on Territorial Affairs, House Interior Committee, letter, 19 July 1977, Reel 334, HLTTA, UHM.

134.

Niedenthal, “Current Trust Funds.” This money was added to the original $3 million granted by Public Law 94-34 in 1975. According to Niedenthal, the trust fund was “liquidated as required by law in December of 2006 and no longer exists.”

135.
Congressional Research Service (CRS), “Appendix A: List of Major Compensation Programs and Authorizations, 1964–2004,” Report for Congress, Republic of the Marshall Islands Changed Circumstances Petition to Congress, 14 March 2005, 37. Public Law 96-126 was passed in 1979.

136.
Memorandum Agreement,
People of Bikini v. Seamans (Civ. No. 75-348) US District Court for the District of Hawai‘i, 27 October 1978, Roll 337, Box 29, RG 200, NAGC, TTPI, NAII.
The agreement was signed by Jonathan Weisgall, attorney for the plaintiffs, and Gary Randall, attorney for the federal defendants (Department of the Interior on behalf of the government of the Trust Territory of the Pacific Islands).

137.
Memorandum Agreement,
People of Bikini v. Seamans, 27 October 1978, NAII.
See also
The People of Bikini, Plaintiffs, v. the United States of America, Defendant, in the US Court of Federal Claims, 11 April 2006.

139.
Weisgall to Joseph, 12 June 1979, NAII
;
Weisgall, “The Nuclear Nomads,” 75
. See also
Bikini Background Briefing Document and Issue Papers, prepared for the high commissioner, Trust Territory of the Pacific Islands, December 1979, Roll 156, Box 13, RG 200, NAGC, TTPI, NAII.

140.
Quitclaim Deed, signed by
Adrian Winkel, high commissioner, Trust Territory of the Pacific Islands, 24 January 1979, Roll 337, Box 29, RG 200, NAGC, TTPI, NAII.
See also
People of Bikini vs. United States of America, 16 March 1981, NAII.

141.
Weisgall to Joseph, 12 June 1979, NAII.
At the time, Weisgall worked for Covington and Burling in Washington, DC. He became the Bikinians’ legal counsel on a pro bono basis and was compensated for expenses, which never exceeded $10,000 per year. See also
Allen to Krause, 19 July 1977, HLTTA, UHM,
and
Office of the White House Press Secretary, press release, 12 August 1968, Roll 339, Box 29, RG 200, NAGC, TTPI, NAII.

142.
DOE, Marshall Islands Radiation and Education and Information Program Plan (Prepared in Response to Public Law 96-205), November 1980, Roll 337, Box 28, RG 200, NAGC, TTPI, NAII.

143.
Jonathan Weisgall, to Cecil Andrus, secretary of the interior, letter, 17 October 1980, Roll 339, Box 29, RG 200, NAGC, TTPI, NAII.

144.
In total, there were ten Americans and approximately 150 Marshallese at the conference. See Scott Stege, TTPI, LNO, Kwajalein, to high commissioner,
“Kili Dose Assessment Trip,” memorandum, 29 October 1980, Roll 339, Box 29, RG 200, NAGC, TTPI, NAII, 1–2.

145.
Verbatim transcript of tape recordings,
“Kili Dose Assessment Trip,” 29 October 1980, NAII, 5.

146.
Verbatim transcript,
“Kili Dose Assessment Trip,” 29 October 1980, NAII, 4–7, 10–12.

147.
As Bruce Wachholz, a representative from the Department of Energy, explained, “We do not have those numbers with us on this trip” but “we can do it through their legal counsel.” See verbatim transcript,
“Kili Dose Assessment Trip,” 29 October 1980, NAII, 5.

148.
Verbatim transcript,
“Kili Dose Assessment Trip,” 29 October 1980, NAII, 5–6.

149.
Verbatim transcript,
“Kili Dose Assessment Trip,” 29 October 1980, NAII, 4, 7.

150.
Verbatim transcript,
“Kili Dose Assessment Trip,” 29 October 1980, NAII, 9.

151.
Verbatim transcript,
“Kili Dose Assessment Trip,” 29 October 1980, NAII, 8, 15.
The three islands vaporized by the American nuclear tests were Bokonijien, Aerokojlol, and Nam. See Niedenthal, For the Good of Mankind, 91. See also
Taro Lokebop (sp?), to high commissioner, letter, 11 April 1969, Roll 339, Box 29, RG 200, NAGC, TTPI, NAII.

152.
Verbatim transcript,
“Kili Dose Assessment Trip,” 29 October 1980, NAII, 9.

153.
“Kili Dose Assessment Trip,” 29 October 1980, NAII, 10.

154.
Verbatim transcript,
“Kili Dose Assessment Trip,” 29 October 1980, NAII, 8, 24.

155.
Senator Henchi Balos, Mr. Jonathan Weisgall, Dr. Gordon Law et al., summary meeting notes, 10 November 1980, Roll 339, Box 29, RG 200, NAGC, TTPI, NAII, 1.

156.
Senator Henchi Balos, government of the Marshall Islands, to the high commissioner, Saipan, telegrams, 22–23 July 1981, 29–30 September 1981, Roll 337, Box 29, RG 200, NAGC, TTPI, NAII.
According to these telegrams, there were 639 Bikinians living on Kili and 130 on Ejit at this time. See also Senator Henchi Balos et al., 10 November 1980, NAII, 3–4. During this meeting, the participants also discussed the “current food shortage at Kili.”

157.
Senator Henchi Balos to the acting deputy high commissioner, tele gram, 23 July 1981, Roll 337, Box 29, RG 200, NAGC, TTPI, NAII.

158.
 
Jonathan Weisgall to Adrian Winkel, high commissioner, Trust Territory of the Pacific Islands, letter, 3 March 1981, Roll 337, Box 29, RG 200, NAGC, TTPI, NAII.

159.

The relevant phrase in the Fifth Amendment of the US Constitution states “nor shall private property be taken for public use, without just compensation.”

160.
People of Bikini vs. United States of America, 16 March 1981, NAII.

161.
People of Bikini vs. United States of America, 16 March 1981, NAII.
When this suit was filed, all fourteen members of the Bikini Council were named in the petition.

162.
High commissioner to secretary of state, telegram, 6 March 1981, Roll 337, Box 29, RG 200, NAGC, TTPI, NAII.

163.
CRS “Appendix A,” Report for Congress, 14 March 2005, 37–38.

164.
Niedenthal, “Current Trust Funds.” According to Niedenthal, these funds (granted in 1988) were also used for “construction and resettlement activities for Bikinians living on Kili Island and Majuro Atoll, including Ejit Island.” See also
CRS, “Appendix A,” Report for Congress, 14 March 2005, 37.

166.

Walsh, A Marshall Islands History, 398. The plebiscite was held on 7 September 1983.

167.
Adam Watkins et al., “Table II-D: Required Distributions of Section 177-Created Nuclear Claims Fund,” in
“Keeping the Promise: An Evaluation of Continuing US Obligations Arising Out of the US Nuclear Testing Program in the Marshall Islands,” Harvard Law Student Advocates for Human Rights (April 2006): 7, http://archives.pireport.org/archive/2006/April/MarshallIslandsReport.pdf.
See also Niedenthal, “Current Trust Funds.” As Niedenthal points out, $2.4 million was distributed annually to the total population of Bikinians in quarterly per capita payments. The other $2.6 million was deposited annually into a trust entitled “The Bikini Claims Trust Fund” (US Public Law 99-239). This trust fund, which was designed to exist in perpetuity, provided each Bikinian approximately $550 per year.

168.

Agreement between the Government of the United States and the Government of the Marshall Islands for the Implementation of Section 177 of the Compact of Free Association, http://www.nuclearclaimstribunal.com/177text.htm. CRS, Report for Congress, 14 March 2005, 32–37, 41.

169.
Tomaki Juda, mayor, Bikini/Kili/Ejit local government, to Leonard Mason, letter, March 1988, in Mason, From a Time of Starvation to a Time for Hope.

170.
“Bikini Day 1988,” Marshall Islands Journal, 18 March 1988,
in Leonard Mason, From a Time of Starvation to a Time for Hope. According to this article, Mason and US Representative Sam Thomsen were present at the celebration.

171.

See Memorandum of Decision and Order, 5 March 2001, 4, 18 (fn. 24). Although Dial Leviticus was born after the end of the nuclear testing program (in 1971), evidence presented to the tribunal indicated that he had been exposed to approximately 1600 mrem of radiation (above background levels) over a period of 2.3 years. Although the full amount for lymphoma was $100,000, it is unclear if the Leviticus family ever received the award. For a list of amounts established for various personal injury claims to the NCT, see http://www.nuclearclaimstribunal.com. Note also that Dial lived on Bikini with his parents and three siblings, all under the age of twelve. The other fifteen families who lived on the atoll also had small children. See List of Names and Members of Families Residing at Bikini, 31 August 1977, NAII.

172.

Memorandum of Decision and Order, 5 March 2001, 4, 13, 16.

173.

After reviewing expert testimony, the NCT recommended soil excavation and removal; periodic application of potassium fertilizer; comprehensive surveillance of soil and crops; and the disposal of contaminated soil through “an elevated and sealed causeway.” See Memorandum of Decision and Order, 5 March 2001, 12.

174.

Memorandum of Decision and Order, 5 March 2001, 16. The question of damages was heard in stages, with the loss-of-use portion of the claim heard on 6–7 May 1998 and the rehabilitation and other consequential damages portion heard from 29 September through 1 October 1999.

175.

Nuclear Claims Tribunal, Republic of the Marshall Islands, Report to the Nitijela for the Calendar Years 2009 and 2010, 1–2.

177.
People of Bikini v. United States, Supreme Court of the United States, Petition Denied, 2 April 2010, http://www.bikiniatoll.com/SupremeCourtDenial.pdf.reference

178.
Lawrence Livermore National Laboratory, Marshall Islands Dose Assessment and Radioecology Program: Bikini Atoll, updated 23 July 2012, https://marshallislands.llnl.gov/bikini.php.

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