CERCLA, DERP, FUDS, and other programs all relate to clean-up after the fact, they don't control how the military handles hazardous waste while a base is active

CERCLA, DERP, FUDS, and other programs all relate to clean-up after the fact, they don't control how the military handles hazardous waste while a base is active or under activated conditions. As I pointed out, nearly all the closed military bases that were shut down through BRAC (around 350) after the Cold War ended are now on the SuperFund list (which is administered under CERCLA). All the older FUDS sites were converted to SuperFund sites if they hadn't finished cleanup (most hadn't). One specific example that's local and relevant to me was the shut down of Kelly Air Force Base as part of BRAC, and the dumping of firefighting chemicals for aviation fires that contained PFOAs and PFOSs that contaminated local groundwater: https://www.sacurrent.com/the-daily/archives/2019/09/26/lasting-harm-the-contamination-around-the-south-sides-air-force-facilities-remains-and-residents-say-its-still-taking-a-toll https://www.sacurrent.com/the-daily/archives/2019/09/26/last... Kelly was closed under BRAC in 1995, and then partially re-opened in 2001 through BRAC as a re-alignment to become Kelly Field, part of JBSA Lackland (previously Lackland AFB). During the closure in 1995, firefighting chemicals which contain toxic PCBs, including PFOA and PFOS, were dumped directly onto the ground where they ran off into the Leon Creek watershed, and still cause the waters to be toxic for swimming, fishing, or drinking today... that watershed feeds drinking water supplies for a significant portion of the city, a portion that happens to be one of the poorest areas of the city. Most of the firefighting chemicals dumped were from the 1970s but were still stored "just in case" until the base got BRACed and then they dumped them... in the 90s, well after PFOA and PFOS were established to be toxic (although the case against Dupont surrounding them was still ongoing and undecided until 2005). So yeah, the Air Force and EPA have committed to a clean-up. Fantastic. No ETA, and the reality is that it's /extremely/ difficult to filter PFOA and PFOS out of water, even reverse osmosis isn't 100% effective. Meanwhile there are hundreds of thousands of people who are drinking contaminated water, swimming in contaminated streams, ponds, and lakes, and being exposed to contaminated fish. Being obligated to do a clean-up "eventually" is not the same thing as being regulated from doing the dumping of toxic waste in the first place. That's my point.