Texas Has 87 Active Installations in DoD Cleanup, 93 Formerly Used Defense Sites. The Program Does Not Count Asbestos.

The Department of Defense keeps a public ledger of its environmental cleanup. For Texas, that ledger is one of the heaviest in the country, and it never once says the word asbestos.

The Defense Environmental Restoration Program publishes a state-by-state status table. The most recent edition, current as of September 30, 2024, records for Texas: 87 active installations with open Installation Restoration Program cleanup sites, 9 BRAC (closed-base) locations, and 93 Formerly Used Defense Sites. The estimated cost to finish that work runs past $2.6 billion across the three categories.

What the table does not do is separate asbestos from every other contaminant. There is no line for it. There is no published, per-installation asbestos inventory anywhere in the federal record. For a state whose military building stock was largely raised before the 1972 OSHA asbestos standard, the one exposure that defines the mesothelioma risk is the one the accounting will not name.

That gap, and a second one in how veterans are told their benefits work, is what this investigation maps.

The Cleanup Ledger

The DERP table is the closest thing to a public scoreboard of military environmental liability, and Texas sits near the top of it.

The program splits its accounting into three buckets. Active installations are still-operating bases. BRAC locations are bases closed under Base Realignment and Closure rounds. Formerly Used Defense Sites are properties the military once held and has since let go. Texas carries a substantial load in all three.

Active installations: 87 with open cleanup

For still-operating Texas bases, the FY2024 table records 87 installations with open Installation Restoration Program (IRP) sites and 19 with Military Munitions Response Program (MMRP) sites. The IRP site count totals 1,111, of which 92 are still in investigation and 44 in active cleanup. The estimated cost to complete is about $838 million.

BRAC: a $1.0 billion closed-base bill

The closed Texas installations carry 9 locations with open IRP sites, 1,212 IRP sites in total, and an estimated $1.0 billion cost to complete. Kelly Air Force Base in San Antonio, closed in the 2001 BRAC round, is part of this closed-base universe and had documented asbestos in its WWII-era physical plant.

FUDS: 93 sites and the demolition work class

The Formerly Used Defense Sites bucket records 93 Texas installations with open IRP sites and 145 with MMRP sites, at an estimated $789 million to complete. The MMRP work class matters here: munitions-response and site-clearance work routinely involves demolishing pre-1980 structures, the exact activity that disturbs intact asbestos-containing material.

One claim this investigation will not make is a national ranking. The same DERP table shows California larger than Texas on every IRP metric. The point is not that Texas is first. The point is that a multi-billion-dollar Texas military cleanup is fully documented at the state level while the asbestos share of it is documented nowhere.

The Texas Base Map

Joint Base San Antonio is the largest military complex in Texas, created in October 2010 when the Department of Defense consolidated three independent installations into one footprint. Each of the three carries its own pre-1980 building history.

Lackland Air Force Base: the WWII frame-building cohort

Lackland’s earliest physical plant traces to June 1941 construction as the Kelly Field annex. The base history records frame buildings with asbestos siding for the rapid wartime expansion. The base became the San Antonio Aviation Cadet Center in July 1942 and the Air Force’s basic military training hub after the war.

From 1966 to 1970, four 1,000-person dormitories were built in steel and brick. The older temporary WWII frame and asbestos-siding structures stayed in use until removal began in 1976, per the JBSA-Lackland fact sheet.

Fort Sam Houston: 19th-century construction still in operation

Fort Sam Houston dates to 1845 and is the historical home of the US Army Medical Department. Its 19th and early 20th century construction includes the Quadrangle (1879) and the Long Barracks (1888). The post hosts Brooke Army Medical Center and the Defense Health Agency headquarters, with pre-1980 building stock layered over more than 130 years.

Randolph AFB: 1928 origin

Randolph AFB, founded in 1928, was the “West Point of the Air” for cadet flight training. Its Spanish Colonial Revival administrative buildings and original hangars date to the late 1920s and early 1930s. The base hosts Air Education and Training Command.

Beyond JBSA: the rest of the installation map

Texas hosts at least eight other major Department of Defense installations, each with its own founding date and pre-1980 building stock:

• Fort Cavazos (formerly Fort Hood, renamed May 2023) near Killeen. Established 1942.
• Fort Bliss in El Paso. Established 1848, expanded heavily during World War II.
• Sheppard Air Force Base in Wichita Falls. Established 1941.
• Dyess Air Force Base in Abilene. Tye Army Airfield 1942, Dyess from 1956.
• Goodfellow Air Force Base in San Angelo. Established 1940.
• Laughlin Air Force Base in Del Rio. Established 1942.
• Naval Air Station Corpus Christi. Established 1941, with a shipyard-adjacent exposure cohort along Corpus Christi Bay.
• Naval Air Station Kingsville. Established 1942.
• NAS JRB Fort Worth (predecessor Carswell AFB, 1941). See Fort Worth-area mesothelioma counsel.
• Red River Army Depot in Texarkana. Established 1941.

Bases raised in the 1940 to 1942 WWII buildup used asbestos-containing materials extensively across barracks, hangars, steam plants, and infrastructure. Bases predating 1940, including Fort Sam Houston and Fort Bliss, add 19th and early 20th century structures with their own asbestos history.

What the Pre-1980 Construction Means

The OSHA general industry asbestos standard (29 CFR 1910.1001) took effect in 1972, and federal facilities were covered from the start. But asbestos-containing materials already installed in pre-1972 construction stayed in place for decades, removed only as buildings were renovated, demolished, or disturbed by major work.

Documented applications at pre-1980 military bases span nearly every building system: thermal pipe insulation, boiler plant lagging, structural fireproofing, vinyl asbestos floor tile, asbestos cement panels and siding, popcorn ceilings, gaskets, electrical insulation, and roofing. Base steam plants used asbestos insulation extensively on hot piping and boilers.

The occupational specialties with the highest documented asbestos exposure cluster in the maintenance and construction trades, not the combat-arms cohort:

• Building maintenance personnel and boiler plant operators
• Pipefitters, plumbers, electricians, and carpenters
• Sheet metal workers and HVAC technicians
• Construction battalion (Seabees) and military civil engineering units
• Aircraft maintenance personnel and vehicle mechanics

Personnel housed in older WWII-era barracks had ambient exposure even without a trade assignment, and family members were exposed to take-home asbestos dust carried home on work clothing.

The Benefits Misconception

The most repeated statement about veterans and mesothelioma is wrong, and the error pushes people toward the wrong claim. Across advocacy and law-firm pages, mesothelioma is described as a VA “presumptive” condition. It is not.

Mesothelioma does not appear on the 38 CFR 3.309 presumptive lists. The PACT Act of 2022 (Public Law 117-168) did not add it. The VA’s own presumptive service-connection materials reference mesothelioma only as an exclusion from the Agent Orange soft-tissue sarcoma category.

The actual pathway is direct service connection under 38 CFR 3.303, developed under the VA Adjudication Manual M21-1 asbestos guidance. That route turns on three things: documented in-service asbestos exposure consistent with the veteran’s military occupational specialty and duty history, a current mesothelioma diagnosis, and a medical nexus opinion linking the disease to the service exposure.

The distinction is not academic. A presumptive condition shifts the burden off the veteran. A direct service-connection claim does not, which is precisely why the documented exposure history at these pre-1980 Texas installations matters to the evidentiary record.

Once service connection is granted, mesothelioma is rated 100% under 38 CFR 4.97, Diagnostic Code 6819, which carries full disability compensation, VA healthcare, and, where a death is service-connected, Dependency and Indemnity Compensation for a surviving spouse. The VA Beneficiary Travel program reimburses approved travel for service-connected care, which can be significant for veterans traveling from West Texas to the Houston specialty bench.

A Closing Thesis

Two public records define the Texas military asbestos question, and both are organized so the answer never quite appears.

The Defense Environmental Restoration Program documents a Texas cleanup backlog past $2.6 billion across 87 active installations, 9 BRAC locations, and 93 Formerly Used Defense Sites, with the costliest work class being the demolition program that disturbs old construction. Asbestos is in that work. The accounting just does not count it as asbestos.

The benefits record has the opposite problem: it is widely described in a way that is simply incorrect. Mesothelioma is not a VA presumptive. It is a direct service-connection claim, which makes the documented exposure history at these aging Texas installations the load-bearing evidence rather than a formality.

What a Texas veteran, or a family member, cannot get from any single public source is the join of the two: which installation, which building era, which trade, and therefore which exposure record supports a claim that the VA will not presume. The broader Texas mesothelioma picture shows where the diagnosed cases are concentrating. The military layer of it is documented in fragments that the federal government has chosen not to add up.