Raspberry falls dangers of water wells in limestone karst geology-final
1. Raspberry Falls Community
Ferry Road, in Loudoun County, Virginia
206 approved 4-‐6 bedroom homes
Public Golf Course community
Now served by a single well shared with Public
Golf Course
Contact People:
Holly Krauss hkrauss70@aol.com
Mitchell Zuckerman mitchell.zuckerman@sothebys.com
1/24/2011 1
2. The Raspberry
Falls Development
is approximately
1 mile away from
the Town of
Leesburg limits
1/24/2011 2
3. Issues Specific to Water 3-‐D Image of Limestone Geology Types of Pollution that
Wells Located in can Influence
Limestone Geology Limestone Geology
Because surface water can rapidly Water Wells
enter into the groundwater system
Because of the rapid transport of
and move quickly through channels
water from the ground surface in
created in the limestone rock, private
karst terrain, there is a high risk of
drinking water wells located in karst
pollution. Streams and surface
aquifers are more susceptible to
runoff that enter sinkholes or
contamination than those in other
caves bypass the natural filtration
types of aquifers.
http://www.loudoun.gov/Default.aspx?tabid=2353 through the soil and provide a
#issues direct conduit for contaminants to
enter the groundwater. Because
Two main types of groundwater in karst aquifers
pollution that can travels quickly, contaminants can
be transmitted quickly to wells and
influence karst geology other drinking water sources in the
water wells. areas connected to that aquifer.
Nonpoint-‐source Pollution
Nonpoint-‐source pollution comes from
a widely distributed source, and is not Point-‐Source Pollution
easily identified. It's also called "runoff Point-‐source pollution enters into
pollution." Types of nonpoint-‐source the groundwater supply or aquifer
pollution can include: through an easily identified distinct
-‐Runoff from golf courses, roads, and location through a distinct route.
parking lots Most of the pollution that enters
-‐Soil washed from farm fields & karst aquifers will be from
construction sites nonpoint-‐source pollution;
-‐Animal waste from feedlots however, there are some instances
-‐Waste from failing [septic] drainfields Abandoned wells, old hand-‐dug farm wells, and cisterns often where pollution may occur from
-‐Pesticides from lawns represent direct connections between the surface and the karst point-‐source pollution. Potential
-‐Trash dumped in sinkholes, and aquifer. Abandoned wells should be properly plugged with clean types of point-‐source pollution
-‐Fertilizers rock (in the water zone) and sand-‐cement grout (to the surface) to that may occur are:
1/24/2011 prevent runoff from migrating directly to the groundwater. -‐Wastewater 3
-‐Leaking fuel storage tanks
4. Raspberry Falls Community Water System
DIAGRAM OF TREATMENT AND DISTRIBUTION
Undersized 40,000 gal Storage Tank
Treatment
Chlorine Disinfection by
injection of Sodium
Hypochlorite prior to
storage
Pumps, Pump Facilities, and Controls
Distribution System
Water Source
1/24/2011 4
7. To our Delegates of the Virginia General Assembly
From the Raspberry Falls Community, Leesburg, Virginia
Draft Amendment to 15.2-‐2110 of the Virginia Code
"D. If any component well in an existing community water system, which has more than 50
connections to individual residences and is located in a karst geology area of the Commonwealth,
is found to have been determined by the Virginia Department of Health to have Groundwater
Under the Direct Influence Of Surface Water ("GUDI") contamination or to be the source of non
potable water, or to pose any threat of contraction or spread of any infectious, contagious or
dangerous disease, or to have failed in any other way and further, if any water main or other
source for a Municipal System piped water supply is located within 3 miles of a community with
a GUDI or failed component well as defined above, then in the interests of public health, safety
and welfare, all users and/or the service provider operator of such existing community water
system shall be entitled to connect to said water main or Municipal System source of piped
public water to the community. Said users and/or the service provider operator of the existing
community water system may be charged a reasonable fee for the connection to the water
main or the Municipal System, comparable to such fees charged to other users. If the service
provider operator of the community water system and the operator or owner of the Municipal
System are different entities or located in different localities, the owner/operator of
said Municipal System nevertheless shall be obligated to provide water, without
objection, subject to an agreement for reasonable charges for the water provided from the
Municipal System source based on the reasonable cost of providing said central piped
water. Homeowners in a karst geology area of the Commonwealth who rely on private wells
within the service area of any community with an existing community water system component
well which is found to be GUDI or to have failed as described above, shall have the same rights,
privileges and obligations as users of the community water system. A special tax district may be
established in order to finance any construction or other costs, charges or fees associated with the
provision of water under this section of the Code."
1/24/2011 7
8. Digging into history of Loudoun's Limestone Overlay District
Sunday, June 6, 2010
"It's like a sponge with holes," said Alex Blackburn of
the county's Department of Building and
Development, adding that many areas are susceptible
to collapse and that underground passageways can
carry pollutants into neighboring wells.
Don Michael, a well driller whose bits have pierced
area house sites, said: "It's like a maze underneath
there. Water travels so fast it doesn't have a chance to
get purified. A cavern can then fill in with a pastelike
mud, thick as mashed potatoes -‐-‐ the residue of
dissolved rock that doesn't get carried off with the
water." http://www.washingtonpost.com/
1/24/2011 8
9. Loudoun Water Communications That Concern Us
Q. Where did the groundhog theory come from, what are their qualifications,
and explain how a groundhog hole is acting as a conduit for bacteria entering
the water table?
A. There are several sinkholes in the Raspberry subdivision. Many of these
sinkholes have groundhog holes in them. We have no idea how complex
the warrens are and how many groundhogs are in them. They are,
however, in sinkholes -- the depressions that accumulate water and can act
as direct conduits to the groundwater. Rain events could very easily wash
pollution from animal droppings or decaying carcasses from the warrens
into the groundwater. Licensed hydrogeologists identified the groundhog
holes and have clearly stated in a draft report that they are a potential
source of contamination. The closer a potential pollution source is to a well,
the higher the likelihood of the source actually impacting the well. This
likelihood is increased if the source is up gradient (generally uphill) of the
well. The closest groundhog holes are within a few hundred feet of one of
the drinking water wells for Raspberry Falls and are up gradient from Well
#1.
Source: Loudounwater.org Raspberry Falls Q&A
1/24/2011 9
10. Raspberry Falls Community -- Map
Location of
Nine (9)
Decaying
Buffalo
Carcasses
on
Wright
Farm
Property
Yellow small tacks = identified sinkholes
Small red = septic tanks and drainfields Big White Tack = Planned RF Well F
Small green = test wells
Small blue = private wells
1/24/2011 10
Big tacks = community wells, golf course irrigation wells, plains of Raspberry well, community waste sys
11. Location of
Nine (9)
Decaying
Buffalo
Carcasses
on
Wright Farm
Property
Feb 2010
Visible
Sinkhole
1/24/2011 11
12. Loudoun Water Communications That Concern Us
INCIDENT: In February 2010, residents discovered approximately 9 buffalo carcasses and countless skeletons
intentionally dumped at the border between the Wright Farm and Raspberry Falls. The topography was wet and
sloped downward from the dump site to the well head area for Well #2. We made the assumption that the products
of the decomposing buffalo were draining through Karst fissures into our groundwater. These include bacteria,
parasites, toxic chemicals and viruses which are not addressed by chlorine disinfection of our water supply. What
tests did Loudoun Water perform to check for such pathogens? Why did the county health department not seek a
the dead animals into the reservoir, there is no doubt that the health department would have initiated a criminal
investigation. How is this incident any different?
Bison
Information About Bison (March 11, [2010] 5 pm)
Loudoun Water is aware that a farm adjacent to the Raspberry Falls property
lost some bison over the winter and those animals were left to die on the
property. We have no knowledge how or why they died. Animal Control
investigated and "is not concerned." The property owner plans to move (or
has moved) the carcasses further from their property line. Loudoun Water
took samples of raw water (prior to treatment) and finished water (after
treatment) for analysis on Tuesday as part of its regular weekly monitoring
protocol. Results from this week and last week were normal. The Raspberry
Falls well water is safe to drink and use as normal.
http://www.loudounwater.org/view.aspx?id=913&terms=raspberry
1/24/2011 12
13. Zone of Influence Around
Raspberry Falls Primary Well #1
Pile of Trash
and Debris Golf Club leaf composting pile of more than 500 cubic feet
At
Golf Course
Maintenance The self-policing efforts
Facility
of the residents of
Raspberry Falls
resulted in the clean-up
of this Golf Course
1/24/2011
Maintenance area 13
14. Loudoun Water Communications That Concern Us
Q. Where is the contamination coming from?
large leaf/mulch pile on the golf course was the
source of bacteria finding its way into the well,
since once that pile was cleared away, we saw
bacti readings return to normal. But a subsequent
round of sampling showed a similar spike.
Geologists believe that a series of groundhog
holes within the karst are one of the possible entry
points for rain and surface water that naturally
carry bacteria within them.
Source: Loudounwater.org Raspberry Falls Q&A
1/24/2011 14
15. A LONG TERM WATER
SOLUTION FOR
RASPBERRY FALLS SHOULD NOT INVOLVE
PUTTING MORE HOLES IN THE GROUND
1/24/2011 15
16. Zone of Influence Around
Raspberry Falls Primary Well #1
Commercial Dumpster
Commercial Fuel Sludge Pit from Golf
Storage Tank Course Maintenance
Vehicle Washdown
Sludge Pit
Sludge Pit (Close up) (after rainfall)
The self-‐policing efforts
of the residents of
Raspberry Falls
resulted in the clean-‐up
of this Golf course
maintenance
area
1/24/2011 16
17. Information about PW-1 GUDI Determination
November 24, 2010
Dear Raspberry Falls Resident,
On November 23, 2010, Loudoun Water was officially informed by the Virginia
Department of Health (VDH) that the results of a six-month series of tests on Well
PW-
Under the Direct Influence of Surface Water or GUDI. If a well is labeled GUDI,
the degree of treatment required for the untreated water is the same as that
required for untreated water pulled from a surface water source. Therefore, once
we were first informed by VDH on November 16, 2010, that a GUDI determination
was possible, PW-1 was immediately taken out of service.
http://www.loudounwater.org/view.aspx?id=1251&terms=raspberry
Why is Well PW-1 now considered GUDI when it wasn t before?
The nature of water wells in karst geology is that any well
could become GUDI over time. This situation is not unique to
Raspberry Falls. Other water wells throughout the Shenandoah
Valley have also become GUDI over time. More information
about wells in karst geology is provided by Loudoun County
government and can be found by clicking here.
http://www.loudounwater.org/view.aspx?id=99&terms=raspberry
1/24/2011 17
18. RF Questions for Dr. Wes Kleene
1. How could current development plans based on community well systems ever have
been approved for a community in a known Limestone Karst geology when the county
hydrologist recommended against it? Over 10 years ago, the potential impacts
regarding contaminated drinking water were already known. There were Identified
sources of contamination within Raspberry Falls and adjacent properties: EPA
Impaired Streams (e-‐coli & coliform), sinkholes, un-‐lined storm water ponds, bison
farm, dairy farm, private alternative septics, chemical storage tanks, medical
psychiatric facility, golf course, improperly abandoned wells, waste water treatment
plant.
2. Initial source water studies for well 1 & well 2 specify both wells at high risk for source
water contamination. Why was no filtration required? Why have special waivers been
requested and issued to not test for fertilizer, poisons, and chemicals knowing we live
on a golf course in karst?
3. How was VDH recently able to determine the bison farm (riddled with sinkholes) is not
a contamination source to our wells as it is about 700 feet away from well #2? RF
hydrogeological experts have noted RF wells could potentially draw contaminations
from up to 23 kilometers away?
1/24/2011 18
19. RF Questions for Dr. Wes Kleene
4. What steps were immediately taken when Loudoun Water and the Virginia Office
of Drinking Water became aware that there was a significant spike of e-‐coli in
Raspberry Falls Well #1 raw water in 2006? When specifically was the event
recorded? When specifically was the well shut down from further production?
issued?
5. How many boil water alerts have been issued? Have any boil water alerts not been
issued when they should have been? How many, when, for what reason?
6. When was the public golf course added to the Raspberry Falls residential water
system?
7. Why did the golf course shut down their drinking water well?
8. When the public golf course was added to Raspberry Falls water system did the
number of users reflect the type and frequency of testing? How has Loudoun
Water increased type and frequency to reflect the true number of people living in
Raspberry Falls? How many people are permitted to use RF drinking water wells?
How many people are actually drinking from RF wells, including public facilities and
commercial useage?
1/24/2011 19
20. RF Questions for Dr. Wes Kleene
9. How many wells have been drilled in Raspberry Falls? How many are able to produce a viable
drinking water source?
10. Why did VDH need to grant a special exception to Loudoun Water for well F? Has well F been
approved? Has Well F shown indicators of surface water influence? What has taken so long to bring
Well F on line as it was promised in 2009?
11. Aside from Well F and well #2 are there any other viable drinking water sources in RF? Any that do
not require a special exception?
12. Given that Well #2 has been found to have high levels of algae, consistent coliform, e-‐ coli, protozoa,
and pollen; why is an immediate, temporary solution not already in place to provide residents with
safe water given the significant possibility that conditions responsible for the recent VDH
Groundwater Under the Direct Influence of Surface Water (GUDI) determination may apply to all
wells within our community?
13. Since well #2 has become Raspberry Falls only source of drinking water numerous people have
complained of GI issues and rashes. 3 Calls were made within the past 2 weeks from residents to
Loudoun County Health Department. No calls have been returned, why?
14. In 2008, the EPA offered to perform a dye trace study that would show which RF wells are GUDI. The
dye trace test was requested in November 2009, with an expected start date of May 2010. Why has
Loudoun Water prevented the study? Will EPA be fully supported in performing the critical dye trace
Loudoun County, Loudoun Water, contractors, builders, business owners, land owners, or any of
their representing attorneys attempting to manipulate the way the EPA wants to conduct their
study?
1/24/2011 20
21. RF Questions for Dr. Wes Kleene
15. In 2009, the Virginia Department of Health (VDH) declared Raspberry Falls Well #1 was
not GUDI despite clear evidence to the contrary. Evidence included bacteria and algae
in the well that spiked with rain. This was clear evidence that surface contamination
flows through karst channels into the groundwater acquifer without being filtered by
soil particles. After the residents of the Raspberry Falls community sent multiple letters
to the VDH in 2010 documenting the errors of the 2009 review, VDH reversed itself and
declared the well GUDI. In 2011, VDH and Loudoun Water say the backup well #2 is not
GUDI. Given the statement by the head of Loudoun Water that wells in karst may
become polluted over time, and the error by VDH in its 2009 finding, knowing well #2
has shown e-‐coli, coliform, algae and pollen, why should we believe their statement
that well #2 is not GUDI ?
16. In January 2010, LW stated it would add a UV filter, increase the capacity of the storage
tank and make the fire hydrants operational. More than a year has passed. Not a single
promised improvement has been made and our primary well has been shut down due
to bacterial contamination. Why is it taking so long when our health is at risk?
17. Why are Van Metre and K. Hovnanian still selling homes in this community and
connecting more homes to the community well water system when it's now clear the
current community well system is overtaxed, over permitted capacity, contaminated,
unsustainable, and there is no alternate solution in place yet?
18. One of the options being reviewed is construction of a filtration plant for the
community well system. What experience does Loudoun Water have in constructing
and maintaining such a plant?
1/24/2011 21
22. RF Questions for Dr. Wes Kleene
19. Some members of the Loudoun County Board of Supervisors have declared that the
Loudoun County Comprehensive Plan prohibits extension of public water to the
Raspberry Falls community. We have read the plan and find no such restriction.
Specifically what restriction is being referenced?
20. The Mayor of the Town of Leesburg says she will not extend public water past
Leesburg town boundaries. However, the Town of Leesburg allowed public water to
be extended to the Dupont Equine Center outside the town boundary immediately
South of our community. Further, the Town of Leesburg extended water utilities to
the newly built Tuscarora High School (also originally outside Town boundaries)
which is located 1 mile South of the Raspberry Falls community. Why does the
Town of Leesburg make exceptions for some but not others? Given the issues of
public health associated with a contaminated water supply, why is a special
exception not being made for our community?
21. Some members of the Loudoun County Board of Supervisors have stated that
Raspberry Falls is located in a rural district. How can this statement be true since the
County approved the developer's plan in 1990 to construct a golf course and 200
homes on primarily 1 acre lots? How is that consistent with preserving a district of
farms and horse pastures? If the goal was to preserve a rural district, why did the
county construct a large new high school campus in the same district (Tuscarora
High School, Leesburg, VA)
http://cmsweb1.loudoun.k12.va.us/Tuscarora/site/default.asp
1/24/2011 22
23. RF Questions for Dr. Wes Kleene
22. Does the VDH or Virginia Department of Environmental Quality regulate the water
quality of the stormwater pond located on the Raspberry Falls property? Why is
this pond not lined to prevent seepage of runoff contaminants into the
usage of fertilizers or pesticides all of which may seep into or runoff into the
23. Did the Raspberry Falls Golf Course originally have their own drinking water well?
Was this well abandoned? For what reason?
24.
Non Compliers (Waterworks) for enforcement targeting?
25. It is our understanding that Raspberry Falls Golf Course irrigation wells are
drawing 200,000+ gpd and Raspberry Falls potable drinking water well is drawing
100,000+ gpd from our groundwater aquifer located in Karst geology. The
developer is continuing to sell homes and add connections to our fragile
community well. Could you please lay out the potential long term impacts of over
pumping of wells especially relating to formation of sinkholes, altercation of
sinking/losing underground streams, and structural damage to homes and
underground water/sewer pipes? Does it make sense to reduce connections of
high production wells, thus reducing the burden for the aquifer in this heavily
populated area, noting a municipal water supply is approximately 1 mile
away? Does it make sense to stop future exploration for potable water wells in
this contaminated area?
1/24/2011 23