BEFORE
THE NUCLEAR CLAIMS TRIBUNAL
REPUBLIC
OF THE MARSHALL ISLANDS
____________________________________________
In
the Matter of
)
The Alabs of Rongelap, et al,
)
NCT No. 23-02440
Claimants for Compensation )
Rongelap
Atoll Local Government/Rongelap Local
)
Distribution
Authority, Intervener
)
___________________________________________
)
In
the Matter of
)
Jabon on Rongelap Atoll
)
NCT No. 23-05443-B
)
and
)
)
In
the Matter of Rongerik Atoll
)
NCT No. 23-05445-B
Ronglap Atoll )
By
Iroij Anjua Loeak, et al, )
Claimants for Compensation )
___________________________________________
)
In
the Matter of
)
Iroij Imata Jabro Kabua
)
NCT No. 23-00501
Ronglap Atoll )
Claimant for Compensation )
___________________________________________)
MEMORANDUM OF DECISION AND ORDER
The
Alabs of Rongelap filed a class action for damage to property with the Nuclear
Claims Tribunal on
November 11, 1991. The Tribunal has jurisdiction to hear his claim by virtue of
Section 105(a) of the Marshall Islands Nuclear Claims Tribunal Act 1987, as
amended (“NCTA”) which grants the duty and responsibility to “decide
claims by and disburse compensation to the Government and citizens and nationals
of the Marshall Islands under Section 123 for existing and prospective loss or
damage to person or property which are based on, arise out of or are in any way
related to the Nuclear Testing Program . . . ”
Unlike other class action claims for damage to property brought before
the Tribunal by local governments/Local Distribution Authorities (LDA’s) as
class representative, the claim filed by the Alabs of Rongelap specifically
excluded certain property interests including the Iroij interests.
As a result, during the process to establish the class, certain
individual property claims were consolidated with the claim of the Alabs.
In addition, the Rongelap Local Government/Rongelap Local Distribution
Authority (RLDA) intervened in these consolidated claims on January 23, 2001.
I. BACKGROUND
FACTS
As was done in prior cases, factual issues were narrowed during the
pre-hearing process with stipulations and joint statements resulting in the
following undisputed facts. Prior
to World War II (and during the war before the arrival of the U.S. military,)
people resided on the three atolls of Rongelap, Ailinginae and Rongerik.
On Rongelap, there were three principal villages on Rongelap, Jabon, and
Eniaetok Islands. On Ailinginae, the principal village was located on Enibuk
Island, and on Rongerik, the principal village was located on Rongerik Island.
Rongelap
Atoll is made up of approximately 61 islands and islets comprising a land area
of approximately 3.2 square miles with a lagoon area of approximately 400 square
miles. Ailinginae Atoll is made up
of approximately 26 islands and islets with a combined land area of
approximately one square mile and a lagoon area of approximately 41 square
miles. Rongerik Atoll is made up of
approximately 15 islands and islets with a combined land area of approximately
0.8 square miles and a lagoon area of approximately 55 square miles.
The
United States’ first series of atomic weapons tests in the Marshall Islands in
1946, referred to as “Operations Crossroads,” resulted in the removal of the
people of Rongelap by U.S. military authorities to a tent camp on Lae Atoll for
approximately three months. Thereafter,
the people were resettled back to Rongelap and Ailinginae Atolls, but
resettlement of Rongerik was restricted. Subsequently,
the U.S. military authorities resettled a group of people from Bikini at
Rongerik Atoll as part of “Operation
Crossroads.” On March 1, 1954,
the United States detonated the “Bravo” nuclear bomb on Bikini Atoll.
Substantial radioactive fallout from “Bravo” began falling on the
Rongelap people approximately five hours following the blast.
Approximately 50 hours after the “Bravo” detonation, the U.S. Navy
removed the Rongelap people residing on Rongelap and Ailinginae to Kwajalein due
to the contamination resulting from the fallout from “Bravo”.
From
1954 until their return in 1957, the Rongelap people lived first on Ebeye
Island, Kwajalein Atoll, and then on Ejit Island, Majuro Atoll under various
circumstances of deprivation, hardship, and distress. During February 1957, the Rongelap people were informed
by the United States Government, through the Atomic Energy Commission and the
Trust Territory Government, that it was safe to return to Rongelap Island, and
in June of 1957, the Rongelap people were returned to Rongelap Island, but were
warned not to resettle or eat food from the northern islands within Rongelap
Atoll.
Notwithstanding
the admonition against eating local food from the northern islands, inadequate
and infrequent supplies of food were brought to the people of Rongelap,
resulting in visits to the northern islands for food gathering purposes.
In
1982, the U.S. Department of Energy published the results of the 1978 aerial
radiological survey of the northern Marshall Islands, including Rongelap Atoll.
The findings of this report, and subsequent reports, suggested that
significant radioactive contamination continued to make Rongelap unsafe for
habitation. As a result, the people of Rongelap again left their islands
and resettled principally on Mejatto Island within Kwajalein Atoll.
In 1999, work began on a resettlement project for Rongelap Island
involving remediation and cleanup of the island for future habitation by the
people of Rongelap.
II. RESTORATION
The Tribunal has previously ruled that the cost of remediation is an appropriate category of compensation for damage to property, resulting from the Nuclear Testing Program (see In the Matter of the People of Enewetak [1] and In the Matter of the People of Bikini.[2])
A. The 15 mrem standard
The
Tribunal adopted the U.S. EPA cleanup levels for radioactive contamination in a
consolidated action, including the present claim, to address appropriate
radiation protection standards for cleanup purposes.[3]
As stated in the Enewetak decision:
Those
standards, established by the U.S. Environmental Protection Agency, are
described in an EPA document entitled "Establishment of Cleanup Levels for
CERCLA Sites with Radioactive Contamination," wherein it is stated:
Cleanup should generally achieve a level of risk with the 10-4
to 10-6 carcinogenic risk range based on the reasonable maximum
exposure for an individual. . . .
If a dose assessment is conducted at the site [footnote omitted] then 15
millirem per year (mrem/yr) effective dose equivalent (EDE) should generally be
the maximum dose limit for humans.[4]
This 15 mrem dose applies not
just to the average resident, but also to those persons experiencing high end
risk or to the “reasonably maximally exposed individual”[5]
and
is over and above existing levels of background radiation, including a component
from global fallout.
The
EPA has given guidance for determination of the “reasonably maximally exposed
individual” (RMEI):
.
. . actions at Superfund sites should be based on an estimate of the reasonable
maximum exposure (RME) expected to occur under both current and future land use
conditions. The reasonable maximum
exposure is defined here as the highest exposure that is reasonably expected to
occur at a site. . . the intent of the RME is to estimate a conservative
exposure case (i.e., well above the average) that is still within the range of
possible exposures.[6]
Additionally, the EPA
states:
The
high end of the risk distribution is, conceptually, above the 90th
percentile of the actual (either measured or estimated) distribution.
The conceptual range is not meant to precisely define the limits of this
descriptor, but should be used by the assessor as a target range for
characterizing “high-end risk.”[7]
B. Current Dose
Experts in this case have evaluated current doses that people would
receive if they were residing on Rongelap, Ailinginae, and Rongerik utilizing a
number of different methodologies. These calculations show that the RMEI would
exceed 15 mrem.
Claimants’ experts, John Mauro and Hans Behling of S. Cohen and
Associates (SCA,) provided two different methodologies for determining the
relevant doses. SCA reviewed the
methodology utilized by the Lawrence Livermore National Laboratory for
calculation of Rongelap doses:
The result of the Robison 1994 analysis predicts an
estimated maximum dose equivalent (EDE) of 0.26 mSv/yr (26 mrem/yr) above
background to the average member of the island’s population in the year 1995
for Case 1 (Combination diet) an .048 mSv per year (48 mrem/yr) for Case 2
(local diet). In both cases, 11 mrem is from external exposure and the remainder
is from food ingestion.[8]
In addition, SCA cites the work of Simon (1997),
which found annual doses based on a 75% local diet range from an average of 28
mrem to a high end of 174 mrem.[9]
Using EPA guidelines for assessing the RMEI, SCA determined there were two
significant variables, diet and high end contamination locations:
Two
independent sets of modeling assumptions are required in order to determine the
high-end doses and health risks attributable to the RME individual:
-
The diet and living habits of the RME individual (which we refer to as the
“exposure” scenarios)
-
The radionuclide concentrations in the environment and in the food items at the
high-end locations on each of the islands (which we refer to as the “source”
scenarios.)[10]
SCA analyzed doses using four
different diets for the Rongelap people, two “combination” diets which
consisted of local and imported foods, and two “local-only” diets, which
consisted entirely of foods from Rongelap.
The Tribunal determined in Enewetak
that a local foods only diet was appropriate for determination of the
reasonably maximally exposed individual.[11]
In evaluating the effect of high-end radionuclide concentrations on dose for a
local foods only diet, SCA determined that doses for Rongelap range from about
100 to 220 mrem/year.[12]
SCA also performed this
analysis for high end doses for Rongerik and Ailinginae Atolls.
In the case of Rongerik Atoll, Cs-137 concentrations and doses are
significantly lower than those on the islands of Rongelap, and in the case of
Ailinginae Atoll, the doses are the lowest of all three atolls, where most of
the islands are close to or below the 15 mrem EDE cleanup criterion.[13]
The Defender of the Fund
retained M.H. Chew and Associates Inc. as its expert to provide an analysis of
doses for the people of Rongelap and of various remediation strategies.
Although the Chew Report found that doses were sufficient to require
remediation, it placed great emphasis on a dietary model of 75% local food, and
25% imported food in calculating doses.[14]
As noted supra, the Tribunal
determined in Enewetak that a local
foods only diet was appropriate for determination of the reasonably maximally
exposed individual.
C. Remediation
Strategies and Costs
All experts agreed that some
remediation strategy would be necessary for the eventual full resettlement of
Rongelap, Rongerik and Ailinginae Atolls in order to safely support future
residents.
SCA considered several
remediation strategies for the clean up of Rongelap, Rongerik and Ailinginae
Atolls. Those strategies consisted
of Soil Removal; Soil Treatment with Potassium/Fertilizer; Soil Washing,
including In Situ Soil Washing; and Soil Immobilization with Zeolite and
Phytoremediation and Plant Cropping.
The costs and effectiveness
of these various strategies varied considerably with some methods exceeding $1
billion. However, at the close of the Tribunal’s hearing on restoration and
remediation, Claimants’ experts and the Defender of the Fund’s expert filed
a written Statement on September 22, 2000, agreeing as follows:
Sanford Cohen and Associates
(SC&A), who is the scientific expert witness team for claimants, and M.H.
Chew and Associates, Inc. (CAI), who is the scientific team for Defender, have
independently evaluated the remediation of the islands of Rongelap, Ailinginae
and Rongerik Atolls. Both SC&A
and CAI agree that a preferred remediation strategy that will be effective in
achieving a cleanup goal of 15 mrem/yr to the high end individual consists of
the application of potassium, supplemented by soil removal and replacement, as
required and as defined by SC&A’s case number 3 and CAI’s report to the
Tribunal. The preferred method for
disposal of contaminated soil is by means of an oceanside stabilized berm or
equivalent. Both SC&A and CAI
agree that the cost for this strategy would be about $212 million. The cost of
this strategy may be adjusted in accordance with any finding by the Nuclear
Claims Tribunal that the acreage is greater or lesser than assumed in the
analysis performed by SC&A and CAI.
Accordingly, the Tribunal
awards the amount of $212,000,000
for remediation and restoration of Rongelap and Rongerik Atolls.
The sum of $193,950,000 is allocated for clean up and restoration of
Rongelap Atoll, with the balance of $18,050,000 allocated for such purposes to
Rongerik Atoll.[15]
III.
Loss of Use.
The people of Rongelap are entitled to damages for the period of time
their use of their property was impaired as a result of radioactive
contamination from the nuclear testing program.
A.
Application of 15 mrem standard to property damages
The Tribunal’s determination that exposures to individuals exceeding 15
mrem/year above background are unsafe and thus interfere with claimants’ use
of their property is guided by U.S. precedent.
Under the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA), cleanup remedies are required to “at a
minimum. . . assure protection of human health and the environment.” CERCLA §121(d)(1).
The U.S. Environmental Protection Agency implemented this statutory
mandate through the National Oil and Hazardous Substances Pollution Contingency
Plan (NCP.) EPA states:
The
NCP provides that, for carcinogens, preliminary remediation goals should
generally be set at levels that represent an upper-bound lifetime cancer risk to
an individual of between 10-4 to 10-6. 40 CFR §
300.430(e)(2) (I)(A)(1). This regulatory level was set based on EPA's conclusion
that the CERCLA protectiveness mandate is complied with "when the amount of
exposure is reduced so that the risk posed by contaminants is very small, i.e.,
at an acceptable level. EPA's risk range of 10-4 to 10-6
represents EPA's opinion on what are generally acceptable levels."
55 Fed. Reg. at 8716 (March 8, 1990). EPA's adoption of this risk range was
sustained in judicial review of the NCP. State of Ohio v. EPA, 997 F.2d 1520,
1533 (D.C. Cir. 1993)[16]
This
risk, furthermore, is not an average risk, but rather is “based on the
reasonable maximum exposure for an individual.”[17]
For radioactively contaminated sites, 15 millirem per year (mrem/yr)
effective dose equivalent (EDE) should generally be the maximum dose limit for
humans. This level equates to approximately 3 x 10-4 increased
lifetime risk and is consistent with levels generally considered protective in
other governmental actions, particularly regulations and guidance developed by
EPA in other radiation control programs.[18]
This 15 mrem/year limit was adopted by the Tribunal as the applicable
standard for determination of contamination of the Utrik lands for the purpose
of assessing loss or damage to property in its January 30, 2004 MEMORANDUM
DECISION AND ORDER in the Utrik claim, NCT No. 23-06103.
The Tribunal determined in Utrik: “In light of the levels of contamination of the subject
lands, the Tribunal finds such lands were unmarketable for their intended use
for the period of time at issue here.”[19]
The subject properties in this claim were contaminated substantially in
excess of those in Utrik.
The Tribunal finds that the lands of Rongelap, Rongerik and Ailinginae
were contaminated so as to result in exposures in excess of 15 mrem/year to the
reasonably maximally exposed individual for the relevant periods of this claim.
As discussed above in the restoration and remediation section, current
doses to the RMEI would substantially exceed 15 mrem for most islands within the
three atolls.
B. Joint
Appraisal Report
The Public Advocate and Defender of the Fund filed a Stipulation in these claims in advance of their experts conducting a joint appraisal on the loss of use of property on April 7, 2000, which stipulated as to periods of denied use as follows:
Rongerik
February 26 to the present
Rongelap
May, 1946 to August 1946 and March 1, 1954 to present
Ailinginae
May, 1946 to August 1946 and March 1, 1954 to present
The Stipulation
also provided that “the Public Advocate and Defender of the Fund shall
instruct their respective appraisers to consider both the fact of occupation of
the subject land by claimants and the alterations to their lands resulting from
the nuclear weapons testing program as well as any restrictions on the use of
the lands by claimants in the opinion of the appraisers regarding establishment
of a loss of use value for the three atolls”.
The Public Advocate and Defender of the Fund submitted a Joint Appraisal[20]
in December 2000, containing loss of use estimates for Rongelap, Rongerik, and
Ailinginae Atolls.
The Joint Appraisal utilized two methodologies
in the analysis. The first methodology, referred to as Methodology A, is similar
to that employed in the Enewetak and Bikini
claims, and relies in paert on “government use” values.[21]
Methodology B consisted of an analysis based on a
residential/agricultural highest and best use. Although the appraisal experts referred to government use
values as being substantially similar to the methodology employed in Enewetak
and Bikini, the expert appraisers in those claims characterized the
highest and best use for the properties as residential/agricultural, and not
government use.
The experts utilized two versions of Methodology A. The first version
consisted of market rent conclusions based on a statistical model of land
transactions through 1979, with 1980 through 2000 market rents based on the
official government rate with five-year rent reviews.[22]
The second version consisted of market rent conclusions based on a
statistical model for the period from 1946 to 2000.
In Version 1, the expert appraisers concluded a loss of use value for the
three atolls of $840,000,000. In
Version 2, the loss of use value conclusion was $790,000,000.
The appraisers considered both versions to be “reliable indicators of
loss in use in value” and concluded that the loss of use value under
Methodology A was $815,000,000 (the average of the two versions) as of the date
of their report.[23]
Methodology
B consisted of a residential/agricultural use approach utilizing criteria
contained in CERCLA and Superfund Acts. This
analysis considered issues such a damage to natural resources; damage to real or
personal property; subsistence use, revenues, and profits and earning
capacities.24 In rejecting this
approach, the appraisers stated:
Based upon a review of these
four types of damages provided under CERCLA, a residential-agricultural use does
not represent the highest and best use of the land, as the values derived from a
governmental land use approach are higher. Indeed the actual use of the land was for government uses,
which further justifies this approach in the final analysis.[24]
C. Highest
and Best Use
The Tribunal had determined in each of the preceding class action
property actions that the highest and best use for the subject properties was a
residential/agricultural use. Nevertheless,
Claimants’ and the Defender of the Fund’s appraisal experts have argued that
the highest and best use for the Rongelap lands is a governmental/military use.
The 2000 Joint Appraisal notes: “It
is impossible to ignore the strong arguments presented under the two possible
highest and best use conclusions.” [25]
The appraisers acknowledged:
Support for the residential/agricultural highest and
best use conclusion is primarily based on ignoring the nuclear weapons testing
program and focusing on the uses which the inhabitants would have logically put
the islands. Such a perspective may
be appropriate if strict U.S. condemnation-style laws are followed. However, the
Nuclear Claims Tribunal has directed that strict condemnation-style law not be
utilized and that all alternative approaches be utilized.[26]
While the Tribunal noted in the Enewetak
case that Tribunal property claims are not condemnation proceedings, in part
because there is no governmental party, it went on to state that constitutional
“principles of just compensation, to the extent that they aid in a
determination of what is necessary to make claimants whole, may be referenced by
this Tribunal where appropriate.”[27]
Whatever the source of the supposed direction not to utilize strict
condemnation law is perceived to be, the Tribunal has consistently determined a
residential/agricultural highest and best use in the three preceding property
loss cases, including circumstances where a more compelling case could be made
of governmental/military highest and best use (Enewetak and Bikini, where the
government actually occupied and made use of the atolls for governmental
purposes.) As the Tribunal
determined in Utrik:
The Tribunal finds the arguments in favor of a
residential/agricultural highest and best use to be persuasive.
The fact of contamination from the nuclear testing at a remote site did
not convert Utrik to a governmental use. It
continued to be used by the people of Utrik, albeit in impaired state, for the
same residential and agricultural purposes for which it had been traditionally
used. The purpose of compensation is to place the injured party in
as good a position as the party would have been in the absence of the injury.
In the absence of the contamination by the nuclear testing program, the
use of the Utrik lands would be for residential and agricultural purposes.
To assume a higher economic use based upon the injury itself, would not
further the goal of compensation, but would rather result in a windfall to the
injured party.[28]
The Tribunal further declared in Utrik:
“The subject Utrik properties are not distinguished from the Enewetak
and Bikini lands in relevant past, current and anticipated future use.”[29]
The Tribunal finds similarly in this case, that the highest and best use
of the subject properties is a residential/agricultural one.
D. Effect
of Highest and Best Use Determination on Valuation
In the cases decided to date by the Tribunal, the differentiation between
residential/ agricultural and governmental/military highest and best use in
rural areas has had little practical effect in terms of valuation of the
properties. In Utrik, the Tribunal stated:
In any case, the question of governmental versus
residential/agricultural highest and best use is largely irrelevant for the
purposes of valuation. Both reports agree in large part that transactional
values for either governmental or residential/ agricultural uses are similar in
rural areas of the Marshall Islands.[30]
This is consistent with the Tribunal’s
findings in Enewetak and Bikini. To be
consistent with the methodologies utilized for calculating
residential/agricultural highest and best use values in previous cases, a
combination of appropriate government and private transactions should be
included in the database. The database of the Joint Report government use
calculations substantially mimics that utilized in residential/agricultural
calculations in Enewetak/Bikini/Utrik.
As noted in the Joint Report itself:
“Methodology A is similar to analyses completed for Bikini and Enewetak
Atolls loss in use appraisal report.”[31]
Consequently, the Tribunal finds that methodology forms an appropriate
basis for determination of lost use values in this case.[32]
E. Effect
of Occupancy
Subsequent to the hearing on the Joint Report, an issue arose in respect
to the instructions given to the appraisers in preparing that report, and the
Stipulation of the Public Advocate and Defender of the Fund with respect to
periods of lost use. The Joint
Report states: “It is noted that the appraisers are aware that the subject
property was occupied by claimants during a portion of the stipulated periods of
lost use. Based on client instructions, we have not considered the temporary
occupation for lost use value purposes herein.”[33]
Nonetheless, the parties had stipulated that the fact of occupation was
to be considered. This resulted in
a protracted process of determining how the fact of occupancy on contaminated
lands should be taken in account in determining lost use, an issue that did not
exist for the most part in the Enewetak and Bikini
claims.
This conundrum was finally resolved in the Utrik
case where the same issue was present, given the Utrik people’s occupancy on
contaminated land after the Bravo detonation. In Utrik, the Tribunal determined that the applicable radiation
protection standard of 15 mrem should control in determining when Claimants have
been denied use of their land:
In determining the applicable
standard for evaluation of what loss the Claimants suffered, the Tribunal will
not ignore a half century of scientific knowledge and policy development.
In the Tribunal’s personal injury program, compensation is not made on
the basis of outdated science. It
has not been suggested that the damage to Utrik lands should be considered on
the basis of contemporaneous knowledge of exposures to the people of Utrik.
Rather, considerable effort has been expended to retrospectively
determine exposures. In like
manner, current standards, which are based on the current level of scientific
knowledge, should be applied. To apply less stringent historical standards
invites the question, “if the land is contaminated now, how could it not have
been contaminated in the past when exposure levels resulting from the
contamination were even higher?”
As a result, the Tribunal believes that the 15 mrem standard as adopted
by the Tribunal in its December 21, 1998 MEMORANDUM OF DECISION AND ORDER should
be the applicable standard for determination of contamination of the Utrik lands
for the purpose of determining loss or damage to property and it is so ORDERED.[34]
The
Tribunal adopted the 15 mrem standard for purposes of determining period of
denied use in these claims in its DECISION AND ORDER of April 4, 2004.
The Defender of the Fund’s appraiser has suggested that the “historic
physical occupancy of the subject property allowed the residents to benefit from
habitation and activity on the land.”[35]
Mr. Captain suggests such benefit should be calculated with reference to
historical regulatory dose limits, with an adjustment to the loss of use values
for such periods as the reasonably maximally exposed individual doses were below
the historical limit. In finding
that lands contaminated above the 15 mrem limit are unmarketable, the Tribunal
has addressed that argument. The
Defender may not circumvent the Tribunal’s ruling in that issue by
characterizing the valuation based on historic radiological standards, rather
than the 15 mrem standard, as an “offset.”
The Tribunal recognized in Utrik that contaminated properties
could have value in use despite their unmarketability, as evidenced by economic
benefits derived from copra production. No
evidence in relation to such economic benefits was introduced in this claim and
consequently the Tribunal is unable to adjust the award on that basis.
F. Joint Supplemental Appraisal Report
A Supplemental Appraisal Report was filed by the Public Advocate and
Defender of the Fund on September 28, 2006.[36]
This report updated the Joint Report filed with the Tribunal on December
2000; refined the original report’s analysis; and applied items of prior
compensation to the loss of use calculations.
The Tribunal has determined that the Joint Report Methodology A provides
an appropriate basis for calculation of lost use in this case.
The Supplemental Appraisal Report, utilizing Methodology A with some
refinements, concluded with loss of use calculations through the year 2000, the
date of the initial appraisal, based on a total land area for all three atolls
(3,166.9 acres) as follows:
Rongelap
Atoll
$460,000,000 less $66,000,000 of prior compensation = $394,000,000
Rongerik
Atoll
$115,000,000
Ailinginae
Atoll
$180,000,000