Raspberry Falls - Loudoun Water's Refusal to Request for Raw Water Testing

February 4, 2011

Subject: Raspberry Falls – Loudoun Water’s Refusal of Request for Raw Water Testing

To: Mr. Mark Petersen, Director of Community Relations Loudoun Water
Mr. Dale Hammes, Manager Loudoun Water
Mr. Fred Jennings - Chairman, Loudoun Water Board of Directors

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
Mr. Jack Roberts, Loudoun County Attorney
Mr. Scott York - Chairman, Loudoun County
Ms. Susan Klimek Buckley - Vice Chairman, Loudoun County
Mr. Jim Burton - Supervisor, Loudoun County
Ms. Lori Waters - Supervisor, Loudoun County
Ms. Sally Kurtz - Supervisor, Loudoun County
Mr. Stevens Miller - Supervisor, Loudoun County
Ms. Kelly Burk - Supervisor, Loudoun County
Ms. Andrea McGemsey - Supervisor, Loudoun County
Mr. Eugene Delgaudio - Supervisor, Loudoun County
Mr. Tim Hemstreet - Administrator, Loudoun County
Mr. Charles Yudd - Administrator, Loudoun County
Dr. David Goodfriend, Director of Loudoun County Health Department
Senator Jill Holtzman-Vogel
Delegate Joe May
Honorable Frank Wolf
Dr. Wes Kleene
Ms. Kristen Unstattd - Mayor, Town of Leesburg
Mr. Kevin Wright - Vice Mayor, Town of Leesburg
Mr. David Butler - Council Member, Town of Leeburg
Mr. Tomas Dunn II - Council Member, Town of Leesburg
Ms. Katie Sheldon Hammler - Council Member, Town of Leesburg
Mr. Fernando Martinez - Council Member, Town of Leesburg
Mr. Kenneth Reid - Council Member, Town of Leesburg
Ms. Jeanette Irby - Attorney, Town of Leesburg
Mr. John Wells - Manager, Town of Leesburg


Dear Mr. Petersen:
This is to confirm our conversation of February 1, 2001, in which we discussed Loudoun Water’s refusal to make raw water available for independent testing on our behalf.
Specifically, you advised me that Loudoun Water will not give Raspberry Falls permission to employ an EPA accredited lab to test our raw water. You further advised that doing so would constitute a “security risk” and would present “chain of evidence” problems. I then explained that the water to be tested would be placed directly in the possession of the accredited lab by Loudoun Water, eliminating any security risk. Again you answered “no”. Finally, you also said that you were under no obligation to respond in writing to our request for raw water, and that the time required to prepare such a response would be prohibitive, given other Loudoun Water priorities. As you have refused to document our conversation in writing, I am doing so myself.
Mr. Peterson, you must know that we are offended by this obstructionist and officious stance. As Loudoun Water knows by now, we are deeply concerned about the safety of our water. This is why we requested an independent test.
While we appreciate that Loudoun Water has agreed to test options for the provision of safe water to our community, we cannot wait any longer to learn about the nature of the raw water being provided to us, as this information critically relates to our health. We would imagine Loudoun Water might welcome an independent test of water from the wells that you insist are safe. It makes no sense to us why such a reasonable request would be refused.
As you will note, I have copied numerous state and local officials, so they may be kept apprised of ongoing process details with the water safety issue within Raspberry Falls.
Sincerely,
Karen Saunders

Too Conservative Website

Please reference too conservative blog. They have been big supporters of Raspberry Falls.
www.tooconservative.com

Response from Loudoun Water in reference to Freedom of Information Act Information Requested

Raspberry Falls Golf Course - Notices of Violations in 2005

Below are links to Notices of Violations for 2005

Feb. 05:
http://www.scribd.com/full/49128389?access_key=key-1l65j2lfsfcweff7cyeo

March 05:
http://www.scribd.com/full/49128386?access_key=key-2bf7pd2eazwawhdlht0c

March 05: Warning
http://www.scribd.com/full/49128390?access_key=key-2b6k861yg39t4hgspxpb

Raspberry Falls Golf Course - Notices of Violations in 2004

There are 4 different violations that can be viewed at the links below:

March 04:
http://www.scribd.com/full/49128164?access_key=key-9ccz6itqauamdkxmwju

June 04:
http://www.scribd.com/full/49128170?access_key=key-14gydhg4iusj2ozqbekg

August 04:
http://www.scribd.com/full/49128160?access_key=key-1dkh7iw9j7hgsnw8o2gi

December 04:
http://www.scribd.com/full/49128382?access_key=key-1jlrqz1ag2u3coi63p9d

Raspberry Falls Golf Course - Notice of Violation 2003

Please view violation at link below:

http://www.scribd.com/doc/49128072/RF-Violation-Nov-2003

Raspberry Falls Golf Course - Violation 1997

Please cut and paste to a new browser to view the 1997 Raspberry Falls Golf Course Violation

http://www.scribd.com/doc/48437597

Virginia Water Resources Research Center - Pathogen Research Symposium - Virginia Tech

If you have time, and if you'd like to know a little more about pathogens in water. This was a good symposium.

http://www.vwrrc.vt.edu/pdfs/specialreports/sr322007.pdf

Raspberry Falls - Environmental Risk & Water Study Options

TO: 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
Mr. Scott York - Chairman, Loudoun County
Ms. Susan Klimek Buckley - Vice Chairman, Loudoun County
Mr. Jim Burton - Supervisor, Loudoun County
Ms. Lori Waters - Supervisor, Loudoun County
Ms. Sally Kurtz - Supervisor, Loudoun County
Mr. Stevens Miller - Supervisor, Loudoun County
Ms. Kelly Burk - Supervisor, Loudoun County
Ms. Andrea McGemsey - Supervisor, Loudoun County
Mr. Eugene Delgaudio - Supervisor, Loudoun County
Mr. Tim Hemstreet - Administrator, Loudoun County
Mr. Charles Yudd - Administrator, Loudoun County
Dr. David Goodfriend- Loudoun County Health Department
Mr. Frank R. Wolf - U.S. Congressman (10th District, Virginia)
Mr. Mark Warner - U.S. Senator, Virginia
Mr. Jim Webb - U.S. Senator, Virginia
Mr. Bob McDonnell - Governor of Virginia
Mr. Ken Cuccinelli - Attorney General of Virginia
Mr. William Bolling - Lieutenant Governor of Virginia
Ms. Jill Vogel - Virginia State Senator (27th District Virginia)
Mr. Joe T. May - Virginia State Delegate (33rd District)
Dr. Wesley Kleene - Director, Virginia Office of Drinking Water
Dr. Karen Remley - Virginia State Health Commissioner
Ms. Kristen Unstattd - Mayor, Town of Leesburg
Mr. Kevin Wright - Vice Mayor, Town of Leesburg
Mr. David Butler - Council Member, Town of Leeburg
Mr. Tomas Dunn II - Council Member, Town of Leesburg
Ms. Katie Sheldon Hammler - Council Member, Town of Leesburg
Mr. Fernando Martinez - Council Member, Town of Leesburg
Mr. Kenneth Reid - Council Member, Town of Leesburg
Ms. Jeanette Irby - Attorney, Town of Leesburg
Mr. John Wells - Manager, Town of Leesburg

DATE: January 20, 2011

SUBJECT: Raspberry Falls – Environmental Risks & Water Study Process Gentlemen:

We would like to thank you again for undertaking a comprehensive water option study at Raspberry Falls. We further want to thank you for recommending to the Loudoun County Board of Supervisors and your subsequent adoption of a resolution last Thursday, January 13, 2011, to include the potential option of connecting Raspberry Falls to public water via the Town of Leesburg.
We want to reiterate that we believe we are in a position to assist Loudoun Water in the identification and evaluation of the various water option alternatives. We propose that a Raspberry Falls resident working group be established to facilitate communication and consultation between Loudoun Water and the residents as the study is designed and implemented.

We respectfully request that the review of all of the options include an analysis of the cost and effectiveness of each estimated working lifespan; the estimated capital andoperating/maintenance cost; the estimated reliability; the experience and track record of Loudoun Water in implementing and operating each; and to political considerations. Finally, on many occasions over the last two years, we have described the numerous environmental risks that influence the groundwater at Raspberry Falls and the resulting health impacts. Although we believe public water will provide the safest, cost effective and most reliable source of water, we are open to the general process. However, if Loudoun Water intends to proceed with an onsite water source, we respectfully request that Loudoun Water, without exception, to research and document via qualified independent experts the following in their comprehensive water study as a prerequisite to any final decision being made:
1.) Allow the EPA to complete their scheduled dye trace study of the wells in Raspberry Falls and Selma to determine directional groundwater flow and narrow the source(s) of the groundwater contamination;
2.) Conduct a full study of the North Springs Behavioral Healthcare (a 77 bed facility) wastewater treatment facility. We believe that large quantities of pharmaceuticals (which are not removed from the wastewater treatment process) are discharged into the local stream. We believe that these pharmaceuticals are leaching into the groundwater supply (not to mention potentially impacting other neighborhoods like Sandy Spring, Big Springs and downstream Potomac water consumers, including one day Loudoun Water).
3.) Conduct a study of the former private airfield at Raspberry Falls and the potential contaminates that is either on or in the proximity of the last remaining well (#2) and the proposed future well (F).
4.) Conduct a full study of the antibiotics used at the adjacent bison farm on the southern side of the community (and the disposition of dead bison) and the potential for leaching into either well (#2) or the proposed future well (F), both less than 1,000 feet away from the bison farm. In addition, study the antibiotics used at the cattle farm adjacent to the northern side of the community.
5.) Conduct tests for 6 continuous and consecutive months for 1.) Semi-Volatile Organic Chemical; 2.) Carbonates; 3.) Volatile Fumigants; 4.) Chlorinated Acidic Herbicides; and 5.) Diquat. We are aware Loudoun Water requested and was granted a waiver by the Virginia Department of Health, Office of Drinking Water (December 20, 2007) to test for these elements.
6.) Conduct a study of nitrates and phosphates for 90 consecutive days during the peak season (a period of time that occurs sometime between April and August). Nitrates and phosphates from homes, the community golf course and adjacent farms are a huge risk in groundwater contamination in our karst environment. Former sampling of nitrates and phosphates has been sporadic and often taken in the “off-season” and, therefore, cannot be considered as representative.
7.) Conduct and publish an updated wellhead protection plan outling the environmental and health risks within and outside the Raspberry Falls community.
8.) Conduct a groundwater study of Selma and estimate the likelihood that one or more wells would be deemed Groundwater Under the Direct Influence of surface water (“GUDI”).
9.) Conduct a study of the health risks associated to long-term exposure to high levels of chlorination, including the impacts to children. Conduct a review and publish a chart of chlorination levels for all wells since the inception of water treatment system at Raspberry Falls.
10.) Conduct a study to find the source that is corroding our copper pipes. In addition, provide an opinion on the long-term financial and legal exposure associated to Loudoun Water relating to pipe failure and the potential health risks associated with the related and potential mold issues. Over 50 residences have experienced one or more copper pipe failures. Dr. Marc Edwards of Virginia Tech stated that “I predict that the rate of failure for this particular fitting in Raspberry Falls will approach 100% over the next 10 years”. Copper Pipe fittings are in numerous places within and outside of our homes.
11.) Conduct a water study of the unlined irrigation pond at Raspberry Falls, which is designed to collect the majority of the storm water run-off from the community, golf course and soon to be treated wastewater from the Raspberry Falls wastewater treatment plant (over 450 residences between Raspberry Falls and Selma and the golf course at build out). The study should outline the direct risks of leaching bacteria, viruses, toxic chemicals and other contaminants into the groundwater table and address the risks of re-circulating this water (in a karst environment) through the golf course and community irrigation systems.
If you choose not to address any of the above, we would like to know why you believe these steps should not be taken in light of risks previously noted.
Furthermore, the residents of Raspberry Falls request access to the raw groundwater samples of the Raspberry Falls and Selma wells from Loudoun Water in order to have independent lab(s) and experts to conduct tests on the samples. You will receive a follow up letter on this request.
Please remember, to date, Loudoun Water has neither identified the source of the groundwater contamination at Raspberry Falls nor identified the cause of the resulting health impacts.
Finally, please provide a copy of this letter to any expert(s) that Loudoun Water uses to generate any part(s) of the Raspberry Falls water study.
There are very important decisions that lie ahead surrounding the future water source at Raspberry Falls.
We look forward to your response and to participating in the design and implementation of your study.

Letter to Terrance Wharton - Stop Development in Raspberry Falls

TO: Mr. Terrance Wharton, Director Loudoun County Department of Building and Development 1 Harrison Street, S.E. Mailstop #60 Leesburg, VA 20175

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

FROM: Concerned Residents of Raspberry Falls

DATE: January 20, 2011

SUBJECT: Raspberry Falls – Raw Water Testing

Dear Mr. Wharton,

This letter is to ask you to immediately revoke all permits currently in force which authorize building and development activities, either planned or currently underway, within the Raspberry Falls subdivision in Leesburg.
Raspberry Falls residents are served by a community well system and, as you may be aware, we now have serious water contamination issues within our community. In fact, one of our primary wells (PW-1), which had been supplying water throughout the community, was just recently found to be groundwater under direct influence of surface water (GUDI) by the Virginia Department of Health. This prompted the immediate closing of the offending well and we are now left with only one functioning well. As you might imagine, it is of great concern to us that this last remaining well (PW-2) has tested positive in the past for harmful bacteria, algae and other surface water indicators.
Meanwhile, EPA is initiating a dye trace study which, we believe, will demonstrate the entire ground water system which supplies water to Raspberry Falls is GUDI. This determination is inevitable, as our community has been built on limestone karst. In this type of geology, harmful surface water contaminants, including animal waste, fertilizer, pesticides and other harmful agents, are transferred almost immediately to the ground water without the benefit of filtration.
Also, our current means of disinfection is limited to chlorine, which is insufficient to properly treat water, and can be very harmful itself when used at excessive levels. This chlorine has already caused uncommon damage to the copper pipes within our homes, which are designed to last some 25 years. Specifically, dozens of homeowners have experienced pinhole leaks in these pipes after only 5 years, new leaks have been occurring just within the past few weeks, and new water heaters and appliances are breaking down and being replaced due to the corrosive nature of the water supplied to our homes. It has already been determined by a scientist at Virginia Tech that ALL of our
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pipes will fail within 10 years. In his report, he cited “I predict that the rate of failure for this particular fitting in Raspberry Falls will approach 100% over the next 10 years”. Naturally, we fear what this chlorine is doing to our bodies if it is able to corrode copper. While Loudoun Water has added orthophosphates to the water in an attempt to mitigate the chlorine’s effects, this approach has not been working, as is evident from the continued new leaks and continued corrosion we are experiencing.
Finally, our communal water system is under-designed and we have exceeded the permitted capacity, for multiple years, of the two wells that service our community. We first exceeded our permitted capacity when the community was less than 60% built out. Today (as of November 2010) we now have only one well servicing the community and our communal water system is unable to support more connections. Simply put, our communal water system is on the verge of complete failure.
We are working with Loudoun Water and our local government officials to arrive at a satisfactory solution to what has become a crisis situation within our community. However, in the meantime, we believe it makes no sense to allow continued development of new homes within our community until this situation is satisfactorily rectified. In fact, we believe that it is incumbent upon all those involved to ensure development ceases during this critical time. It is vital to protect public health, which is now at grave risk.