I joined the Air Force right out of High School. I wore the Security Police badge from 1981 to 1992. I stood posts on flight lines and trained on installations across the United States. I lived at Kunsan Air Base in Korea for more than a year and at Shaw Air Force Base for ten years. I also served in Jordan and Egypt, and deployed to the United Arab Emirates during the Gulf War. I drank the water where I was assigned. I never thought about it, and neither did anyone I served with.
A new study gives veterans a reason to think about it now. The government's response shows a pattern that should concern anyone who studies public administration. The institution that caused the exposure is still setting the terms for measuring it, and those terms lag behind its own regulators.
The problem
PFAS are synthetic chemicals that persist in the environment and the body. DoD began using PFAS-containing firefighting foam in the 1970s. Release during training and emergencies is a major source of groundwater contamination on military bases.
On September 14, 2026, Brown and Harvard researchers published the first national comparison of PFAS blood levels by veteran status. They analyzed eight National Health and Nutrition Examination Survey cycles from 2003 to 2018. Veterans aged 20 to 39 had PFOA, PFOS, and PFHxS concentrations 13 to 24 percent higher than non-veterans of the same age. Younger veterans were also 18 percent more likely to exceed the National Academies of Sciences, Engineering, and Medicine monitoring threshold of 20 nanograms per milliliter. Older veterans had levels comparable to civilians. That does not clear older veterans. Lead author Christian Hoover said the study's inability to detect a gap in older veterans does not mean they were not at the same risk when they were younger. PFAS leave the body slowly, but they do leave. A man in his sixties may carry a normal level today and still have carried a high one for years.
The paper also reports that 58 percent of veterans across all ages, roughly 13.2 million of a weighted 22.8 million, had a summed level of seven PFAS at or above 20 nanograms per milliliter, compared with 36 percent of non-veterans. That gap is unadjusted. Veterans in the survey are older and more often male. After the authors adjusted for age, sex, race, education, and survey cycle, veterans as a whole were slightly less likely than non-veterans to exceed the threshold. The excess sits in veterans aged 20 to 39. The figure is a survey estimate across 2003 to 2018, not a count of veterans above the threshold today. The survey does not record military occupation, branch, or time since service.
The paper does not prove that military service put the chemicals in anyone's blood. It is a cross-sectional comparison of blood levels, not a study of illness. The researchers say they do not know for sure what caused the elevated levels. They name firefighting foams, munitions, and groundwater contamination as possible sources.
Three groups are affected: veterans who served on contaminated installations, families who lived there, and civilians who live beside the fence line. The federal government is responsible for all three. DoD caused the releases. VA decides benefits. EPA sets the drinking-water standard for public systems.
Shaw Air Force Base in Sumter County, South Carolina, is the local test of how those duties reach a neighborhood. In early 2020, South Carolina regulators sampled 13 community water systems within about three miles of Shaw. Four exceeded the old EPA lifetime health advisory of 70 parts per trillion for PFOA and PFOS, including three mobile home parks and one business. Shaw's September 2023 notice offered water-system connections to properties whose wells reached 70 ppt, with bottled water in the meantime. That notice is evidence of what residents were told then, not proof of Shaw's present cutoff. The Air Force's March 2026 status report counts 56 off-base private wells at Shaw as impacted, a term it defines by the previous 70 ppt action level. Twenty-eight are connected to municipal water, 13 are on bottled water, seven owners declined a response, and the rest are pending, unoccupied, or no longer need action. Three public wells serving mobile home parks remain on bottled water while municipal connections are pending.
DoD lowered its department-wide interim action levels for private wells in September 2024 to 12 ppt for PFOA or PFOS, three times EPA's public-system limit. Yet the Air Force's March 2026 snapshot still tabulated its installations, including Shaw, against the former 70 ppt level, and said it was evaluating existing data against EPA's new limits. That report does not tell me what each household has been offered. It does show that the Air Force's public accounting had not yet been updated to reflect either EPA's 2024 limits or DoD's 12 ppt interim action level. EPA's enforceable 4 ppt limits govern public water systems, not private wells directly. I am not claiming Shaw is breaking that rule. I am arguing it should be the standard. My policy objection remains: a family drinking from a well affected by a military release should not have to wait for contamination to reach three times the public-system limit before DoD offers an enduring remedy.
Kunsan's own annual water reports say PFOA and PFOS were detected but below 70 ppt in 2022 and 2023. The Status of Forces Agreement limits the host nation's access to the installation for independent testing. I will not assign Korean body-burden studies a precise military share. Industry is in that mix. Veterans who served there should still treat exposure as a live question.
The governing system
Four federal actors share this problem. None owns it completely. EPA sets the standard for public water systems. In April 2024, it finalized enforceable limits of 4.0 ppt each for PFOA and PFOS, 10 ppt for PFHxS, PFNA, and HFPO-DA (GenX), and a hazard-index limit for certain mixtures, with compliance due by April 2029. The health-based goal for PFOA and PFOS is zero. On May 18, 2026, EPA proposed keeping the PFOA and PFOS limits while letting eligible water systems request two more years, to 2031. The extension would not be automatic. It also proposed rescinding the other four limits, on the stated ground that those pieces of the 2024 rule did not follow Safe Drinking Water Act procedure. Neither proposal is final.
DoD cleans up under CERCLA. As of June 30, 2026, it had identified 727 active installations, closed bases, Guard facilities, and formerly used defense sites that require PFAS assessment. Preliminary assessments and site inspections were complete at 709. No further action was required at 119. Five hundred ninety are proceeding to remedial investigation and feasibility study. That next step is investigation, not a finished cleanup.
GAO reported in February 2025 that DoD had spent $2.6 billion since 2017, that future investigation and cleanup costs would exceed $9.3 billion from fiscal year 2025 on, and that no installation had reached long-term cleanup as of June 2024. On September 2, 2026, DoD pushed back investigation schedules at 243 installations, the longest by 13 years. It cited expanding investigations and changing standards. An earlier 2026 letter from Senator Slotkin described slips ranging from one year to more than 20 years in a prior timetable.
DoD's September 3, 2024 cleanup policy sets interim action for private wells at three times the MCL, 12 ppt for PFOA or PFOS. DoD said it expects potentially thousands of private wells will need action, more than it can complete at once. That is a real capacity limit. It is also a decision to leave families between 4 and 12 ppt outside the first wave. At least one 2025 Navy notice still used the old 70 ppt figure to decide when to supply bottled water while it arranged an enduring remedy, and listed the 12 ppt levels alongside it.
VA controls testing inside its hospitals and decides disability claims. PFAS testing is not currently available at VA medical centers. A VA spokesperson told Stars and Stripes that physicians can order testing through commercial labs when they deem it medically necessary. VA says it is reevaluating blood testing in light of new federal research. There are no presumptions related to PFAS exposure. VA has been reviewing whether kidney cancer should become a presumptive condition under the PACT Act process. Veterans can still file case-by-case claims with a diagnosis, evidence of exposure, and a medical nexus.
Congress sets the mandates. Section 707 of the Fiscal Year 2020 NDAA requires DoD to provide PFAS blood testing to each DoD firefighter during the annual physical. Firefighters are the only group that the statute covers. The same NDAA barred fluorinated AFFF at land installations after October 1, 2024, with two one-year waivers. DoD used both. The current statutory deadline is October 1, 2026.
What theory reveals
Principal-agent theory. Congress and the public are the principals. DoD is the agent. The agent here is both the polluter and the investigator. It decides which wells get sampled, what level triggers action, and when the investigation ends. That arrangement predicts delay, because every lower threshold enlarges the agent's liability. The move from 70 ppt to 12 ppt, and the refusal so far to treat 4 ppt as the interim private-well trigger, fits the prediction.
Institutionalism. Organizations keep the rules they built. The 70 ppt figure came from a 2016 non-binding health advisory. It became the working threshold for bottled water, hookups, and base water reports. A superseded number still shapes what residents were told and how status charts are organized.
Public choice. Agencies weigh their own budget exposure. VA's public health page says that knowing a blood level "will not tell you whether PFAS has or will cause illness," and leaves the testing decision to the veteran and a provider. That position has a scientific basis. It also shields the department from a large, open-ended claims file. The National Academies took a different view on the medical question. It recommended blood testing for communities with high exposure, then health screening for people above certain levels.
Incrementalism. EPA moved from an advisory to an enforceable standard, then proposed extending compliance and dropping four compounds. DoD moved from 70 ppt to 12 ppt rather than to 4. Each step is small and defensible alone. Together, they mean people near contaminated sites wait longer for relief.
Implementation
Written policy and practiced policy are not the same list. Shaw's 2023 notice used 70 ppt for connections. DoD's 2024 memo uses 12 ppt for interim private-well action. EPA's 4 ppt rule binds public systems, with a 2029 compliance date and a proposed opt-in path to 2031. I have not seen a public Shaw ledger that maps every tested well to the 12 ppt rule. The last threshold Shaw published for residents, in 2023, was seventeen times the federal public-system limit and nearly six times DoD's own 12 ppt interim level.
Staffing and method are the next weak points. Remedial investigation needs hydrogeologists, lab capacity at parts-per-trillion detection, and contractors who can work off-base. When EPA lowered the bar, DoD said it had to go back into the field. Fair. The slips at 243 sites are the cost of that admission. Long-term pump-and-treat at Shaw, reported at about 15 million gallons a month for PFAS and VOCs in the April 2025 environmental newsletter, shows that some installations are past the brochure stage. Most of the 590 are not.
In 2021, the DoD Inspector General found the department had focused narrowly on firefighting foam and had not identified other PFAS sources on its installations. If the source list is incomplete, the cleanup plan is incomplete.
VA implementation has a different hole. Every enrolled veteran can get a toxic-exposure screening. It asks about airborne hazards and burn pits, Gulf War-related exposures, Agent Orange, radiation, Camp Lejeune water, and “other” exposures. VA says the screening relies on veterans’ reports and includes no routine diagnostic test or physical exam. It records what a veteran reports, but it does not put a PFAS lab value in the chart. A test that cannot treat a disease can still change monitoring and can still sit in a claims file.
Military physicians have described the larger failure in plain terms. A 2022 Military Medicine commentary said few clinicians receive training to recognize and manage hazardous non-combat exposures. VA has developed exposure-informed care: veterans report possible exposures during screening, and an Individual Longitudinal Exposure Record brings together data from DoD and VA sources. VA authors acknowledge that individual measurements of dose and duration are often missing. A 2026 review found that only five of 29 eligible military-exposure research repositories used direct exposure assessment; 24 used indirect methods. Those counts describe research resources across many hazards, not PFAS measurements or the contents of my file. I want the VA to record where I served, my duties and housing, and the preventive medicine I was ordered to take. It should explain what exposure is suspected and what a blood result can and cannot establish. It would not prove that water at Kunsan or Shaw caused an illness. It would give my doctor and me a record to work from.
My Gulf War service gives this question a second, personal history. I served in the United Arab Emirates and was ordered to take pyridostigmine bromide, a nerve-agent pretreatment pill, under threat of imprisonment. I also received anthrax and botulinum toxoid shots, a meningitis shot, and other vaccinations. We were given medication to prevent malaria, too. I cannot reconstruct every dose or date from memory, and I am not claiming that those measures or PFAS caused an illness. The National Academies found insufficient evidence to determine whether multiple Gulf War vaccinations were associated with long-term adverse health effects. Its report also describes the consent waiver and weak individual records for pyridostigmine bromide. My experience is one more reason to preserve what each service member received and where each served.
When I came home, we were told not to give blood. In November 1991, military and civilian blood banks restricted donations from Gulf War veterans after leishmaniasis, a parasite spread by sand flies, appeared in returning troops. The restriction ended in January 1993. It was a precaution against infection, not a finding about chemicals, PB, or vaccines. Yet it shows that officials could act on a potential risk across the returning force without first proving each veteran’s individual exposure. I want that same seriousness brought to documenting what happened to us and measuring what can still be measured.
Public safety effects
This is a public safety issue in the strict sense. The risk falls on people who cannot see it, and it falls hardest on those with the least ability to avoid it. Shaw's affected area includes mobile home parks, rental homes, and small businesses. Renters do not control the well and may not receive the notices.
Firefighters face occupational risk, and they are the only group with a guaranteed statutory test. The broader pathway reaches everyone on the installation: water. Security forces, maintainers, cooks, clerks, and their families all drank it.
The same pattern appears off other fences. New York designated Stewart Air National Guard Base a state Superfund site in 2016 after PFAS from firefighting foam reached Newburgh's Washington Lake. ATSDR ran an exposure assessment in Orange County. They are the off-base half of the same plume problem.
The foam transition matters for current responders. Removing AFFF reduces future exposure. The replacement still has to put out jet-fuel fires. A rushed switch that degrades crash-fire response would trade one risk for another. If the October 1 deadline cannot be met, Congress should rewrite it in the open.
Options
Option 1. Keep the current system. Veterans ask a VA physician, who may order a commercial test if medically necessary. Claims are decided case by case. DoD continues CERCLA on the slipped timetable and takes interim well action at 12 ppt. Effectiveness is low for veterans who do not know to ask. Short-term cost is lowest. Testing goes to the informed and insistent, not to the most exposed. Families between 4 and 12 ppt wait.
Option 2. Targeted testing and a published well standard. VA funds PFAS blood testing for enrolled veterans whose service record places them at a DoD-listed installation during a known or suspected release period. Results go into the health record and the Individual Longitudinal Exposure Record. Clinicians follow National Academies screening guidance. Congress requires DoD to report how many off-base private wells fall between 4 and 12 ppt, what residents have been told, and when each well will receive treatment or a clean-water connection. Effectiveness is moderate to high for documentation and monitoring. Cost is bounded by eligibility rules. I could not find a verified per-test cost or a published count of eligible veterans. VA should publish both. A blood level cannot pinpoint when or where exposure happened. That limit is accurate and should be stated every time the test is offered.
Option 3. Immediate presumptive service connection for PFAS-associated conditions at listed installations. Effectiveness is highest for benefits access. Cost is largest and least predictable. The evidence is uneven across conditions. A blanket presumption now would outrun the science. It would also invite a later rollback that harms veterans.
Judgment
Verified facts. Younger veterans carry measurably higher PFAS blood levels than civilians their age. Across all ages, after adjustment, veterans do not. The paper's unadjusted 58 percent figure is accurate but reflects the older, more male veteran population. DoD identified 727 sites requiring assessment and moved 590 into investigation. EPA's enforceable public-system limit for PFOA and PFOS is 4.0 ppt. DoD's 2024 interim private-well trigger is 12 ppt. Shaw's 2023 resident notice used 70 ppt. The Air Force's March 2026 snapshot still counted impacted wells against 70 ppt. VA medical centers do not offer the test on site. No PFAS presumptions exist. GAO's future-cost figure is more than $9.3 billion from fiscal year 2025 onward. Two hundred forty-three investigation schedules slipped in the September 2026 update.
Reasonable inferences. Military exposure is the most likely explanation for the gap in younger veterans. The study did not prove it. Homes near Shaw with water between 4 and 12 ppt from a DoD release are not in the first wave of interim action under the 2024 memo.
Disputed or unverified. The 2018 Kunsan 85 ppt number. Any claim that Shaw is presently violating a legal duty to connect private wells at 4 ppt. Alignment with 4 ppt is my proposed policy for DoD-caused private wells, not a Safe Drinking Water Act obligation that already binds those wells.
My opinion. The government cannot hold veterans to a documentation standard it will not help them meet. A veteran cannot prove an exposure that no one measured, at a base whose records no one kept, using a test the VA will not routinely provide. Off the fence line, a family drinking from a well affected by a military release should not have to wait for contamination to reach three times the public-system limit before DoD offers an enduring remedy.
What would change my view? If the published paper shows the veteran-civilian gap disappears after controlling for occupation, region, and diet, the case for veteran-specific testing weakens. The same is true if VA publishes data showing that testing does not change clinical care. If Shaw publishes a well-by-well ledger showing every well above 4 ppt already connected or scheduled, the implementation charge against that base narrows to the department-wide 12 ppt rule.
Recommendation
I support Option 2. VA should fund PFAS blood testing for veterans with documented service at DoD-listed installations and record the results in their exposure files.
Congress should require DoD to report how many wells fall between 4 and 12 ppt, what residents have been told, and when each well will receive treatment or a clean-water connection. DoD should set a public date for applying the 4 ppt benchmark to off-base private wells from its own releases.
VA should finish its kidney-cancer review under a published deadline. Two years is long enough to reach a decision, either way.
Measures of success
Testing reach: the number of eligible veterans tested within two years, and the share above 20 ng/mL whose records show follow-up screening.
Well accounting: a public count of off-base private wells above 4 ppt near DoD sites, including Shaw, and the share with a permanent solution by 2029.
Decision speed: whether VA issues a kidney-cancer presumption decision, either way, within 12 months.
Health first. Paper second. Nobody is owed a rating for having served near foam. Everybody who served near foam is owed an honest account of what was in the water, and a government that measures it by the current public-health benchmark, not the leftover one.
Sources. Hoover, Costello, and Braun, Environmental Health Perspectives, 14 September 2026; Brown University and Harvard Chan releases; Military Times and Stars and Stripes, 15 September 2026; EPA PFAS NPDWR, 89 Fed. Reg. 32532 (26 April 2024); EPA proposed PFOA/PFOS extension and PFAS rescission rules, 18 May 2026; DoD PFAS cleanup status as of 30 June 2026; DoD September 3, 2024 MCL prioritization memorandum and FAQs; GAO-25-107401; GAO-24-107322; DoD September 2, 2026 schedule update; Air Force PFAS Snapshot as of 31 March 2026; Shaw AFB PFAS fact sheet, September 2023; Shaw April 2025 Environmental Newsletter; SCDES community sampling near Shaw, January to March 2020; The Post and Courier, 2 December 2023; VA Public Health PFAS page; FY2020 NDAA §§ 322 and 707; DODIG-2021-105; Kunsan AB Consumer Confidence Reports, CY2022 and CY2023; NYSDEC Stewart/Newburgh Superfund designation; ATSDR Orange County exposure assessment; NAVFAC notification letter, 22 August 2025. Krahl, Mallon, and Gaydos, “Hazardous Non-Combat Exposures in the U.S. Department of Defense,” Military Medicine 187 (2022), 314-318, doi:10.1093/milmed/usac166. National Academies, Gulf War and Health, Volume 1: Depleted Uranium, Sarin, Pyridostigmine Bromide, and Vaccines (2000), pp. 17-18, 208-209; VA Public Health, “Vaccinations and Gulf War Veterans” and “Pyridostigmine Bromide and Gulf War Veterans.” Lindheimer et al., “An Assessment of Repositories for Researching Military Exposures and Veterans Health,” Military Medicine (12 February 2026), doi:10.1093/milmed/usag026; McAndrew et al., “Exposure-Informed Care: Why It’s Important and How the Veterans Affairs Does It,” Medical Care 64, no. 2S, supplement 2 (2026), S103–S110, doi:10.1097/MLR.0000000000002238. Miller, “Military Environmental Exposures: What All Clinicians Need to Know,” American Journal of Nursing 123, no. 11 (November 2023), 47–52. Army Reserve, “Explanation of Blood Donation Restriction for SWA Veterans,” 27 November 1991; DoD, “Post-Operations Desert Shield/Desert Storm Medical Issues,” 15 September 1993.
