October 15, 2010
Mr. Scott York
Ms. Susan Klimek Buckley
Mr. Jim Burton
Ms. Lori Waters
Ms. Sally Kurtz
Mr. Stevens Miller
Ms. Kelly Burk
Ms. Andrea McGimsey
Mr. Eugene Delgaudio
cc: Leesburg Town Council
Mayor Kristen Unstattd
Vice Mayor Kevin Wright
Mr. David Butler
Mr. Thomas Dunn, II
Ms. Katie Sheldon Hammler
Mr. Fernando Martinez
Mr. Kenneth Reid
Ms. Jeanette Irby
Loudoun Water Board of Directors
Mr. Edward Burrell
Mr. Charles Harris
Mr. Fred Jennings
Mr. Dimitri Kesari
Mr. Mark Koblos
Mr. Leonard Mitchel
Ms. Patti Psaris
Mr. Johnny Rocca
Ms. Tanja Thompson
Mr. Frank Wolf - Congressman of Virginia
Mr. Bob McDonnell - Governor of Virginia
Mr. William Bolling - Lieutenant Governor of Virginia
Mr. Tim Hemstreet - Loudoun County Administrator
Mr. Charles Yudd - Assistant to the County Administrator
Mr. David Poisson - Loudoun County Delegate
Mr. Chuck Caputo - Loudoun County Delegate
Mr. Terry Wharton - Director of Building and Development
Ms. Marcy Cotov - Loudoun County Budget Officer
Mr. Wesley Kleen - Director of Virginia Department of Health
Mr. Hugh J. Eggborn -Field Director with Virginia Department of Health
Mr. Dale Hammes - Director of Loudoun Water
Mr. Todd Danielson - Loudoun Water
Mr. Robert Edleman - Virginia Department of Health
Dr. David Goodfriend - Director of Loudoun County Health Department
Mr. Robert Kieffer - Environmental inspection VDH/ODW
Mr. John Wells - Leesburg Town Manager
Attached you will find a 2 page brief summary of some grievances that the community of Raspberry Falls would like to share in regards to our source water contamination as it relates to our drinking water. We can’t stress enough the importance of the health and safety of this community. Should you have any questions or concerns please direct your corresponance to Holly Krauss at 16616 Elk Run, Leesburg, VA 20176 or via e-mail at hkrauss70@aol.com.
The water supply at Raspberry Falls is contaminated. Raspberry Falls’ wells consist of non-potable source drinking water (attachment A) per VDH groundwater system sanitary report 9/16/09. The contamination is revealed by E-coli, coliform and algae, which have been documented by VDH and Loudoun Water since 2004 (attachment B). In June 2010 Raspberry Falls was put on a Boil Water Alert (attachment C). This is the FIRST time this regulation was followed. For many years there have been multiple occasions and reasons for mandatory boil water alerts, yet none were issued. The regulations that mandate boil water alerts and numerous Public Notifications have been ignored as a result of Loudoun Waters’ mismanagement.
With over 300 water test samples provided to Raspberry Falls homeowners, approximately 80% of these samples are contaminated with E-coli and or coliform. The point source and non-point source of bacterial and contamination in our water is human and animal waste that infiltrates the aquifer through limestone karst geology, sink holes, improperly abandoned wells, failing septic systems (Front 25 homes of Raspberry Falls; Attachment D), local farming practices and sinking springs, and federally impaired streams. These sewage borne bacteria are indicators of contamination which always includes much more difficult to detect pathogenic viruses, parasites and toxic chemicals. They do not occur in isolation and this is well known scientific fact. The source of chemical contamination is pesticides and fertilizers, yet Loudoun Water negligently and repeatedly seeks waivers every three years to avoid testing for these chemicals. VDH erroneously grants these waivers knowing we are a golf course community surrounded by farming practices. In addition, due to the lack of action and timely enforcement of waterworks regulations, Loudoun Water provides homeowners at Raspberry Falls a false sense of security, when in reality our community is continually put at risk. Giving families a false sense of security without all of the facts shows how irresponsible they are and this illustrates a lack of concern for our communities health and safety.
Chlorine and UV treatment (which has been proposed by Loudoun Water as an improvement) are not adequate to disinfect Groundwater Under the Direct Influence of surface water (“GUDI”)(Attachment E). Virus, parasite and chemical contaminants are not eliminated by chlorination and UV treatment. According to Dr. Calvin Alexander, a University of Minnesota hydrologist and leading authority on karst geology who has been consulted by the Raspberry Falls resident’s states, “Chlorine addition to the drinking water is an inadequate treatment that, at best, removes only some of the harmful microbiological contaminants present in the raw water.” (Attachment F) It is for this reason that Loudoun Water treats the raw water that it distributes from its Ashburn plant with a robust multistage filtration and disinfection process and not simple chlorination.
In 2009, VDH/Robert Edleman reviewed the final required laboratory test results in order to make his GUDI determination for Raspberry Falls. Although many of the tests used in his final evaluation did NOT meet the "required EPA Consensus Method testing requirements " Mr. Edleman did NOT exercise his authority to INVALIDATE any of the tests or request additional testing. Mr. Edleman made a decision that he stated was his "JUDGEMENT" call, not taking into account prior sanitary surveys or ANY physical parameters. This information has been confirmed by Mr. Edleman in a public meeting with Loudoun Water, Sally Kurtz (BOS), and the Raspberry Falls Water committee. Mr Edleman had the authority as an engineer working on behalf of VDH/ODW to invalidate tests that did not meet test requirements as well as request additional field work, to validate his "JUDGEMENT CALL". These actions or lack of action are consistent with the oversight of this relatively young water system (2002). The amount of data that is available to VDH/ODW, Loudoun Water and Loudoun County regarding water quality tests, septic issues, mix land use, stream quality, and chemical spills, suggests there are and have been significant contamination issues in our groundwater for decades. We request you make our concerns of Heath and Safety a top priority.
Loudoun Water states on its website that it switches from the Raspberry Falls main well to a back up “less contaminated well” when rain conditions cause the E-coli count in the main well to exceed a limit that Loudoun Water considers safe. This action is an express admission by Loudoun Water that the ground water is under the direct influence of surface water. What else could be the cause of an increase in the bacteria level when it rains, other than rainwater at the surface washing contamination through the karst fissures into the aquifer?
As a result of doubt regarding the VDH non-GUDI finding, the Board of Supervisors asked the EPA to conduct a dye trace test study in November 2009, confirmed by Sally Kurtz (attachment G). The purpose of the test is to confirm surface water is infiltrating the aquifer. To date, the dye trace study has not been conducted despite the completion of the work plan from the EPA. We do not understand why, or who is responsible for impeding the test. Raspberry Falls needs this test be completed, or the Loudoun County Board of Supervisors needs to provide the Raspberry Falls community with central water solutions ASAP.
When the EPA dye test is completed with dye recovered from the surface, which would constitute a conclusive federal government conducted finding of GUDI, we assume all participants will agree the solution is to connect all Raspberry Falls homes (including the 25 original homes supplied by private wells drawing from the same contaminated aquifer) to Leesburg Town Water. After all, when the Loudoun County Board of Supervisors, staff and Leesburg Town Council decided to construct a new high school campus adjacent to Raspberry Falls, it could have drilled wells. Instead, properly concerned that the wells would be contaminated (as warned about in the recently enacted Limestone Overlay District ordinance), the county connected its own property to Leesburg town water. (Attachment H). “The resulting Goose Creek Vulnerability Analysis (CWP, 2002) indicates that the Town of Leesburg's (TOL) subwatersheds currently have levels of imperviousness that negatively impact water quality, and that anticipated growth in the area will not allow water quality [from wells] to be sustained under a build-out scenario.”
In 1990, as the Van Metre development entity was seeking permits for Raspberry Falls, the Loudoun County technical staff and the Loudoun County Planning Commission publicly objected to Van Metre’s plan to provide water in the proposed development from wells, warning that the wells will be polluted (Attachments I,J,K). Even the initial source water studies provided by VDH noted both wells to be highly susceptible to surface water influences (Attachment L).
Loudoun County Board of Supervisors, staff, and Leesburg Town Council clearly understands the vulnerability of wells in the Raspberry Falls region. Section 4-1901 of the recently enacted LOD ordinance: “development on karst terrain has a direct correlation to the potential for … susceptibility of groundwater and surface water pollution, and spring contamination, posing serious risks to public health, safety and welfare.” [emphasis added]. Lest anyone claim that this is a newly recognized risk and that the developer Van Metre could not have anticipated that the wells would become polluted, here is what the deputy director of the County’s natural resources department recommended to the Loudoun Water planning committee in 1990 as Van Metre was seeking permits to develop Raspberry Falls using wells: “The use of a central public water supply should be required utilizing a source located expressly to be safe from contamination.” (attachment M)
What the county’s staff experts ominously warned about in 1990 has occurred. No amount of chlorination and UV treatment will eliminate the clear and present dangers to our health that are present in our drinking water. We need central water because our water is contaminated. Raspberry Falls experiences a public health risk every day and the Loudoun County Board of Supervisors cannot ignore our issues. The residences of Raspberry Falls already experience a multitude of health issues ranging from (i.e.) wide spread skin rashes, GI issues, numbness, to more serious overgrowths of gram negative, antibiotic resistant strains (attachment M). We seek the same solution for our families that the county provided to its own new high school facility next door—connection to Leesburg town water.
We are continually told the extension of public water utilities is a political issue that will result in the growth of 15 North. We (the Loudoun County voting public; concerned residence of Raspberry Falls, relatives, neighbors, employers, and their employees) expect these politics to be put aside and the very real health risks posed to Raspberry Falls families to become your priority.
Thank you for your time and attention,
Concerned Citizens of Raspberry Falls
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