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!
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