Dr. Goodfriend letter to Raspberry Falls Residents

You will find the letter that Dr. Goodfriend, from Loudoun County Health Department, sent to the Residents of Raspberry Falls.

http://www.scribd.com/full/49129067?access_key=key-7068tglrs0j7tqzi8u2

Raspberry Falls - Request Status of System Upsizing

TO: Mr. Dale Hammes - General Manager, Loudoun Water
Mr. Fred Jennings - Chairman, Loudoun Water

CC: Mr. Edward Burrell - Board Member, Loudoun Water
Mr. Pravin Gandhi - Board Member, Loudoun Water
Mr. Charles Harris - Board Member, Loudoun Water
Mr. Mark Koblos - Board Member, Loudoun Water
Ms. Patti Psaris - Board Member, Loudoun Water
Mr. Johnny Rocca - Board Member, Loudoun Water
Ms. Tanja Thompson - Board Member, Loudoun Water
Mr. Ralph Watson - Board Member, Loudoun Water
 
FROM: Concerned Residents of Raspberry Falls

DATE: January 25, 2011

SUBJECT: Raspberry Falls – Request Status of System Upsizing

Dear Mr. Hammes and Mr. Jennings:

On January 8, 2010, Mr. Todd Danielson wrote to your Raspberry Falls customers to outline a series of improvements that would be made to upgrade our water system. He said that the upgrades would include "upsizing" the system's storage and pumping capacity which would, among other things, assure adequate fire flow, and would include installation of fire hydrants. He also committed to replace our primary well with a new well (well F), and add ultraviolet disinfection.

At the time, Mr. Danielson predicted that all improvements will "likely take a year or more to be completed." In the Q & A for Raspberry Falls on your website, dated January 19, 2010, you state that you will be adding fire hydrants that are connected to our potable water distribution system to meet fire flow standards of 500 gallons/minute. You did not provide a timeframe for the addition of the hydrants.

More than one year has passed since you posted this statement via your Q & A. Would you kindly let us know the status of these improvements, including the work that has been completed, and detailing what remains to be completed and an associated timetable for completion?

While we understand that Loudoun Water has agreed to conduct a study of three options for ensuring safe and reliable water for us, we know that the study will take time. In addition, the implementation of the choices made by Loudoun Water and the residents at the conclusion of the study will take additional time. We and our children consume the water that Loudoun Water sells us every day, which means that the upgrades promised to us a year ago should not be delayed pending the outcome of the study. We hope to hear from you informing us in detail to the progress that has been made in implementing the promised improvements.

Raspberry Falls-Dangers of Water Wells in Limestone/Karst Geology

Raspberry Falls – Orthophosphate Treatment

TO: Mr. Dale Hammes - General Manager, Loudoun Water

Mr. Fred Jennings - Chairman, Loudoun Water 

CC: Mr. Edward Burrell - Board Member, Loudoun Water

Mr. Pravin Gandhi - Board Member, Loudoun Water

Mr. Charles Harris - Board Member, Loudoun Water

Mr. Mark Koblos - Board Member, Loudoun Water

Ms. Patti Psaris - Board Member, Loudoun Water

Mr. Johnny Rocca - Board Member, Loudoun Water

Ms. Tanja Thompson - Board Member, Loudoun Water

Mr. Ralph Watson - Board Member, Loudoun Water

FROM: Concerned Residents of Raspberry Falls

DATE: January 20, 2011

SUBJECT: Raspberry Falls – Orthophosphate Treatment

Dear Mr. Hammes,

Raspberry Falls residents are conducting a review of the effectiveness of the orthophosphate treatment that Loudoun Water initiated last year.  As you know, Loudoun Water initiated this treatment to mitigate the damage your water is causing to the copper pipes in our homes.  Results of our survey to date of impacted parties throughout the neighborhood indicate that the addition of orthophosphate to our water has not stopped the corrosion and leaks from occurring.  

To assist us with our assessment, we would appreciate your providing us with responses to the following questions and requests:

1) On what date did the addition of orthophosphate commence?

2) What is the exact composition of the chemical and what is the amount being added to our purchased water?

3) What are the results of any surveys that Loudoun Water has conducted to determine the effectiveness of the orthophosphate treatment?

4) Does Loudoun Water intend to continue the orthophosphate treatment - and for how long? 

5) Are potential buyers of new homes now being sold by Van Metre and/or K. Hovanian being notified of your consultant’s prediction that 100% of all homes in Raspberry Falls that purchase water from you will experience copper pipe failure? 

6) Is any filtration or other mechanical system is being included in such new homes to mitigate copper pipe damage?

7) Has Loudoun Water has added a process or treatment to the sewage plant in order to remove the orthophosphate from effluent before the effluent is discharged into a stream?

8) Are tests being conducted to determine the effectiveness of the process or treatment described in 7) above?  

9) Are buyers of new homes are receiving any indemnity from the seller or Loudoun Water with respect to future copper pipe damage from the water to be purchased from Loudoun Water?

10) Can Loudoun Water confirm that the addition of phosphates fixed the water type and/or pipe corrosion, or will it be necessary for the developer to disclose corrosion issues to new buyers?

We thank you in advance for your prompt response to these questions. 

Raspberry Falls -Raw Water Testing

TO: Mr. Dale Hammes - General Manager, Loudoun Water

Mr. Fred Jennings - Chairman, Loudoun Water 

CC: Mr. Edward Burrell - Board Member, Loudoun Water

Mr. Pravin Gandhi - Board Member, Loudoun Water

Mr. Charles Harris - Board Member, Loudoun Water

Mr. Mark Koblos - Board Member, Loudoun Water

Ms. Patti Psaris - Board Member, Loudoun Water

Mr. Johnny Rocca - Board Member, Loudoun Water

Ms. Tanja Thompson - Board Member, Loudoun Water

Mr. Ralph Watson - Board Member, Loudoun Water

FROM: Concerned Residents of Raspberry Falls

DATE: January 20, 2011

SUBJECT: Raspberry Falls – Raw Water Testing

Dear Mr. Hammes and Mr. Jennings:

In connection with, and to supplement, Loudoun Water's study of various options to provide safe and reliable water to Raspberry Falls residents, we intend to secure tests by an independent laboratory of water from the following sources:

1) The raw water being produced by Loudoun Water wells PW-2 and F at Raspberry Falls;

2) The raw water produced by the Loudoun Water wells supplying homes in the Selma development adjacent to Raspberry Falls (as one of the options is interconnection between the Raspberry Falls and Selma systems);

3) The raw water from any observation well within Raspberry Falls or Selma that are within Loudoun Water's control;

4) The treated water from the water storage tanks at Raspberry Falls and Selma; and

5) The treated wastewater from the Raspberry Falls treatment plant before it is discharged into the community stream.

We would appreciate if you would provide Mrs. Holly Krauss and Mr. Mitchell Zuckerman with the name and contact information for a Loudoun Water employee whom our laboratory can contact in order to obtain raw water from each of these wells.

Raspberry Falls Residents seek state legislators’ help in addressing water concerns

Jan. 7, 2011 - by Crystal Owens, Loudoun Times Mirror

Water woes reigned during a legislative town hall meeting Jan. 6, where dozens of county residents gathered to bring their concerns to state lawmakers before the General Assembly convenes next week for its 2011 session.

Out-of-town customers of the Town of Leesburg’s utility system and residents of Raspberry Falls, a community north of Leesburg that resides on a Limestone Overlay District, dominated the two-hour session with pleas to legislators for help in addressing their issues.

Customers of the utility system appealed to the delegation to propose legislation that would change a state law that allows municipalities to set different rates for water and sewer service to customers who live in an extended service area.

“The current law does not require regulation or oversight.  It creates an opportunity for price discrimination against out-of-town customers who have no consumer protection,” said resident Teresa Bailey.

Many residents who live outside the town limits of Leesburg have battled with Town Council in the form of litigation for five years, seeking equal pricing for their utility service as those who live within the town limits.

In November, the state Supreme Court ruled that under state law the increased water and sewer rates to out-of-town customers is fair. Out-of-towners have reported paying double what in-town residents pay for water and sewer service.

“We need your support because the courts have failed us. We have no recourse. We can’t vote so we have to rely on the legislators doing something in this situation,” said Raymond Baldwin, a resident of Lakes at Red Rock, a community just outside the Town of Leesburg.

In Raspberry Falls, residents are dealing with what they believe to be contaminated water.

The community has been a hot- button topic among Loudoun County leaders recently after the state Department of Health deemed one of the area’s two communal wells to be groundwater under the direct influence of surface water or GUDI. The well since has been permanently shut down and Loudoun Water’s Board of Directors is set to vote Jan. 13 on whether to study an option to extend central water service to the community from the Town of Leesburg.

Residents, fearful that their drinking water is contaminated with harmful bacteria that could be causing illnesses, have pleaded with the Loudoun County Board of Supervisors for a central water option for years.

“I am here because we are not a third-world country,” Loraine Mathis, one of several Raspberry Falls residents who spoke at the meeting told the delegation. “Yet in Raspberry Falls we drink water, we bath in water, we shower in water, we cook in water that is comparable to what third-world countries use. At the same time, we’re paying water rates, we’re paying taxes, we’re paying utility rates that are comparable to everyone else, but we’re not getting our equitable quality of water.”

Susan Jacks, also of Raspberry Falls, asked the delegation to keep the issue from becoming a “political football” among Loudoun County supervisors.

“I ask that you be involved and be available and help us reach a long-term sustainable solution,” Jacks said.

The session was attended by Sens. Mark Herring (D-33) and Jill Vogel (R-27) and Delegates Bob Mashall (R-13), Joe May (R-33), Tom Rust (R-87) and Jim LeMunyon (R-67.)

Raspberry Falls: A Failed Experiment

Raspberry Falls: A Failed Experiment in Community Production Wells Within Limestone Karst A White Paper for Distinguished Members of the Virginia General Assembly

Overarching Message: The community wells that serve Raspberry Falls residents are unsafe and produce water of unpredictable water quality. We are faced with significant health risks and this situation is not sustainable for the long term. The State of Virginia and Loudoun County (LC) lack adequate regulation and protection for developed communities located in Karst environments.

The state of Virginia and LC have failed to make necessary provisions to provide an alternate reliable water source should ground water become contaminated due to unpredictable and unregulated pollution sources. We need your support to ensure this emergency situation receives immediate action, as our health is in serious jeopardy.

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The Raspberry Falls Community and Issues Associated with our Geology: • The Raspberry Falls Golf and Hunt Club (RF) subdivision is located in the Western portion of

Loudoun County along VA State Route 15, three miles north of the Town of Leesburg. • The community is built on limestone karst (LK) geology, which is unique because it features

springs, caves, sinkholes, and other formations which prevent adequate surface water filtration:

http://www.loudoun.gov/controls/speerio/resources/RenderContent.aspx?data=71baf45937fa41d3a9cf4df29c6de17f&tabid=3 10&fmpath=%2fWatershed%2fMap&zoom_highlight=carbonate+map

• The community also lies within the Loudoun County Limestone Overlay District. http://www.loudoun.gov/Default.aspx?tabid=2542

• A public golf course, RF operates within the boundaries of the community. • Neighbors to RF include a bison farm, a psychiatric medical facility, farms, golf course and a new

275 home development. Also, Virginia DEQ-impaired streams traverse the community. • RF is designated as one of the first Loudoun County “rural hamlet” subdivisions approved for 205

single family homes sited on primarily 1 acre lots. • RF is a “Community System” which is owned and operated by Loudoun Water (LW - also known as

Loudoun County Sanitation Authority) www.loudounwater.org. We are served by one communal well and a 40,000 gallon storage tank. Our system has always been undersized, under-designed and unsustainable. Our effluent is treated onsite. Solids are shipped offsite for further treatment and the treated water effluent is discharged into an unnamed tributary of the Limestone Branch stream.

• The first 25 homes within RF are served by individual well and septic systems, a number of which are failing and are further endangering the safety of the water supply to the rest of the community.

• Due to the high volume of groundwater movement and lack of adequate groundwater filtration, our water quality is unpredictable. Groundwater test results often vary on an hourly and daily basis.

• The state lacks appropriate regulation and testing standards for source water within LK. New standards/regulations are needed to protect the health and safety of residents in these areas.

• As we draw contaminants from over 20 kilometers away, many contaminants are unknown, and are neither regulated nor tested. Known contaminants include fertilizers, pesticides, animal waste, pharmaceutical grade antipsychotic drugs, effluent from aging private septic systems and wastewater treatment plant, storm water pond, impaired streams, contaminants from roads, prior chemical spills, and prior land use such as an airstrip.Key Point: Filtration should be something one can depend on. It should not be based on the unpredictable and ever changing environmental conditions. Instead of having the opportunity to slowly percolate through the soil as is the case in most of the country, the surface water which feeds our wells flows directly to the ground water within hours and days!

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Associated Current Health Issues and Risks

• To the best of our knowledge, groundwater contamination was first noted via LW/Virginia Department of Health (VDH) testing in 2006; residents were not notified until 2008. Our first Boil Water Alert was issued in June 2010.

• 2006 - 2007 VDH/ODW groundwater study revealed correlation of significant rain events with bacteria in wells.

• In 2008 additional testing was conducted, however testing protocol/requirements were not met, clearly noting the lack of concern for our health and safety. Test results served The Virginia Office of Drinking Water (ODW) and VDH to support a finding that our wells were not “Ground water Under the Direct Influence of surface water (GUDI). This misrepresented the risk to our families’ health and well being.

• However, in Nov 2010, over four years after the first known LW well contamination, the ODW/VDH determined well #1 to be GUDI.

• In 2009 the EPA agreed to study all community wells via dye tracing and, we believe, will likely uncover the entire system as GUDI and unfit for human use. We have asserted this for over 2 years but the dye trace study has yet to begin.

• We currently have only ONE well to meet our water needs. Many tests of this well have often revealed the presence of coliform bacteria, algae, amoebae and pollen – all surface water indicators.

• To make matters worse, the system has no filtration and relies solely on chlorination as its only means of disinfection. Chlorine does not defeat most surface water contaminants, which our families are exposed to every day.

• Testing results revealed that LW had difficulty maintaining chlorine residuals, as chlorine levels have varied widely from day to day and well to well..

• Copper pipes in the majority of RF homes have experienced pinhole leaks. Dr. Marc Edwards, a VA Tech scientist, asserted that all pipes will fail. If pipes have failed in less than 3 years, what are the health impacts to humans?

Key Point: Our water is at higher risk than for most communities; and yet our water is treated with little more than is used in third world countries! We are at serious risk – NOW!

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Community Development History

• At least a decade prior to the development of our community multiple agencies warned of the eminent risk of ground water contamination, yet these warnings were ignored and no action was taken.

• In 2002 VDH stated that communal wells were at high risk of contamination. • Despite all warnings from LC officials and VDH, LC still permitted the builder, Van Metre (VM) to

develop the RF community and communal well system without any filtration. • The community is riddled with over 50 test, observation and or abandoned wells. • In 2005, the golf course was added to both the water and waste water system. • The Plains of Raspberry, a historic mansion where weddings are frequently held is also serviced by

waste water system.

Key Point: Development of additional homes without investigating the known issues and securing a solution unnecessarily puts more Virginians at risk. Our issue will extend to our neighbors as well!

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Associated Political Issues

• Future development along the Route 15 corridor has been (and remains) a significant political issue. Outside groups have lobbied the LC Board of Supervisors (BoS) to restrict development.

• The Town of Leesburg provides fully treated public water (via the Potomac) to its residents. • In the past, Leesburg town wells were abandoned due to contamination; central system now provides

water. • Leesburg boundaries recently extended to include new Tuscarora high school due to high risk of

contamination and environmental conditions. School property is less than 2 miles from RF.. • In 2009, BoS passed establishment of a “Limestone Overlay District” (LOD) which stated intent to

protect karst environment and groundwater quality. But its regulations were silent on potential

contamination of community production wells. • The unabated development and proposed drilling of new wells runs counter to stated LOD intent. • Plus, new development will quicken/change/re-route ground water flow, limit natural filtration even

further, and encourage the development of additional sinkholes, further endangering us/our homes. • BoS voted on January 4, 2011 to recommend the LW Board include consideration of all options in

remedying our water issues, including a public water option.

Key Points: Expanding the already unsustainable use of community production well systems, which have proven to be a failure, makes no logical sense and is a dangerous strategy. Dependable, safe public water is less than 2 miles away from our community!

Summary and a Call to Action

• We are pleased that our elected officials have recommended to LW that they study all options for providing RF and neighboring communities with a safe, sustainable water source.

• We urge all involved to move quickly to provide us with clean, potable water immediately. • We urge the General Assembly to approve new legislation that will direct county and local

authorities to take immediate corrective measures to restore safe water to any failed community system. In the instances where such systems are within reasonable distances of public water systems, the local authorities should undertake interconnection with such public water system(s).

• Meanwhile, we also ask the General Assembly provide oversight to ensure that no groups, or organizations or agencies impede or slow down the process. We request any recommended solution is sustainable, ensures the greatest protection of health and safety, cost-effective, and achieved in a reasonable time frame.

• RF residents ask that we be directly involved in the upcoming study process.

Our health is already in serious jeopardy and must be placed in front of all other concerns. Current logistical and political obstacles can be remedied. Our health, once lost, cannot be!

Letter to Loudoun Water for Water Study Options

January 11, 2011

Mr. Dale Hammes

Mr. Fred Jennings

We are both pleased and relieved that the Loudoun County Board of Supervisors, at the recommendation of Loudoun Water, agreed to include the study of a public water option in the water study for Raspberry Falls, and thank you profusely for your consideration of this important matter.  

This study and the resulting actions are very important to bring a permanent solution to Raspberry Falls.  The selected option should provide a solution which is financially feasible, sustainable and provides the lowest risk in order to protect the health and safety of all users of the Raspberry Falls water system.  You are well aware of Raspberry Falls’ history, risks and substandard design, including the unpredictable environmental conditions, unregulated land use activities and the inoperable fire hydrants that exist. 

We understand that the various options include a water filtration system, the feasibility of interconnecting the Raspberry Falls and Selma water systems, and the public water option, and that the study would provide a comprehensive analysis of the pros and cons of each alternative.  In order to present a fair comparative analysis, all water solutions should be analyzed over the same period of time based on the solution with longest sustainable life period.  For example, the average life expectancy of a public water pipe is 60 to 75 years (and sometimes longer).  We would expect that each solution would be modeled for the same period of time (factoring in capital improvement and/or replacement costs, even if it happens multiple times during the comparative period).  We further expect that any analysis provides both a net present value (“NPV”) and internal rate of return (“IRR”) analysis for each solution over the comparative period.  The public water option should consider connecting to the source closest to Raspberry Falls – the Leesburg water main that was extended to Tuscarora High School.  The study should also include, for all options, provision of service to the first twenty-five homes of Raspberry Falls which are on individual wells, given the substantial health risk that exists for those families with their aging systems as well as the risk that their septic systems pose to the near-by community wells.

We believe we are in a position to assist Loudoun Water in the identification and evaluation of the various alternatives, and consideration of the financial impacts of the various alternatives.  The inclusion of citizen input will help assure that the residents will better understand the study process and the subsequent evaluation, reduce confusion afterwards as to the study and evaluation process and better assure that the conclusions can be implemented without undue delay due to possible misunderstandings.  We have a number of residents who are highly qualified in matters of this nature, and will be pleased to provide you several names.  

We would also suggest that the study identify the source(s) of funding for each of the options, including the responsibilities of the developer(s) of Raspberry Falls.  A 20 year projected rate study with comparison to current charges should also be made to assist the residents to understand the financial impact on their personal situation. We believe that we can, together with the Loudoun Water Staff, put together a transparent and comprehensive study plan to satisfy all expectations and questions.  Given the urgency of the matter, time is of the essence, and we urge that the study begin immediately.

We look forward to your response.

Loudoun Water approves pipeline study - Loudoun Times, Crystal Owens

Loudoun Water’s Board of Directors agreed Jan. 13 to study the option of a central pipeline extension to a community north of Leesburg.

The study will explore costs and quality of water associated with a pipeline extension from the Town of Leesburg to Raspberry Falls, a community of about 250 homes operating on communal wells.

One of the two wells serving the community was shut down Nov. 16 after the state Department of Health determined it was groundwater under the direct influence of surface water or GUDI.

The determination means the well was more susceptible to contamination.

Loudoun Water agreed to the study, which will be developed through an agreement with the Town of Leesburg, after a Jan. 4 request from the county Board of Supervisors.

In addition to the pipeline option, Loudoun Water also will study water treatment options for Raspberry Falls and nearby Selma Estates.

Article from the Washington Post-Rasbperry Falls, Testing the Pipeline Waters

Dated: Jan. 13th, 2011

Testing the Pipeline Waters

After years of complaints about water quality in a community near Leesburg, the Loudoun Water board of directors will vote Thursday on whether to fund a study examining the possibility of extending a central water pipeline from Leesburg to Raspberry Falls, a subdivision north of town and west of Route 15.

After numerous appeals by Raspberry Falls residents asking that the county consider all possible options to address their water problems, the Loudoun County Board of Supervisors voted Jan. 4 to request that Loudoun Water fund the study.
The situation in Raspberry Falls intensified in November, when one of the two communal wells that provides water to 134 homes in the community was permanently disconnected after the Virginia Department of Health issued a violation notice saying that the groundwater was found to be under the direct influence of surface water.
The remaining well is capable of sustaining indoor water demands during the winter, according to Loudoun Water, and a new well is expected to be operational in time for rising demands in the spring.

Raspberry Falls is in Loudoun County's "limestone geology" area, meaning that the communal wells are surrounded by rocky terrain that does not filter surface water as effectively as sand or soil. Contaminants, including bacteria, pesticides and fertilizers - such as those present on a nearby buffalo farm and golf course - can more easily make their way into the untreated water supply through channels in the limestone.
Along with instructions that the contaminated well be shut down, the state Health Department requested in November that alternative sources be developed, including the possibility of connecting Raspberry Falls to Leesburg's water system.
But the idea of even considering a connection to Leesburg's waterworks was met with some opposition. Supervisors Stevens Miller (D-Dulles) and James Burton (I-Blue Ridge) voted against the study, and Burton pointed out that the water tested by the state Health Department was untreated, whereas all treated samples showed no bacteria.
"The treatment options that are available are more than adequate. We have heard from Loudoun Water that the drinking water is safe," Burton said. "The idea of running central pipes out there sets a bad precedent."
Because Raspberry Falls is part of a rural zoning area, the extension of a central pipeline from Leesburg would require that the supervisors first vote to rezone the community in the county's general plan.
Greg Branic, a member of the Raspberry Falls homeowners association, said that resistance to extending the pipeline is more about the politics of development in a rapidly growing county than addressing a legitimate health problem.
"This is a public safety hazard," Branic said. "It's frustrating for the residents, because it's been really poorly managed and mishandled."
Despite anecdotal accounts of illnesses attributable to water quality problems, David Goodfriend of the state Health Department reported that he had seen no conclusive cases involving residents sickened by contaminated water, although some cases of gastroenteritis had been observed.

But residents of Raspberry Fall say ailments observed in the community are most likely caused by the contaminated water.

"Even my own kids have had skin rashes, horrible rashes all the time," Branic said. "People in the community have had a lot of gastrointestinal problems."
One child in the neighborhood had a more serious medical issue that required surgery, he said.
"Again, nobody can say, 'Hey, that happened because of the water,' " he said. "But, like I asked two of the supervisors, 'Can you look me in the eye and tell me it's not the water?' "
Several doctors who live in Raspberry Falls have also voiced concerns that the levels of chlorine needed to treat the water are bad for the residents' health, Branic said.
"All we want is clean water, from the safest source that costs the least amount of money," he said.

Dale Hammes, general manager of Loudoun Water, said at the meeting that he would recommend to the Loudoun Water board that the study be funded.
"It is something our customers have asked for. . . . Furthermore, I think if the question is left unanswered, I think it will plague the path forward. I think it will be something that will continue to delay our progress, which we are keen on pursuing as time is of the essence," he said.