Inadequate
Mitigation
Sea Level Rise Mitigation
What MVSD Wrote (Deck presented 9/11/23)
“One of the highest priority concerns for the Mill Valley MS Site.
Grade / Elevation changes
Shore up Wetlands
Levees or Sea Walls
Building & Site Resiliency”
Our Lingering Concerns
Grading and elevation changes can help at the site itself, but access to the site will likely be compromised during rainy winters. Grading changes also risk disrupting the soil cap currently keeping the hazardous soils from becoming airborne. As groundwater rises, soil contaminants will continue to surface, as they are already doing, per the Notice of Violation that MVSD received in March 2024. MVSD has no budget, ability, or intention to build a new levee or sea wall, as that would need to be coordinated and funded by the City. “Building and site resiliency” is vague and meaningless.
The flooding is at its worst at the temporary site (see existing signage there about parking at your own risk due to flooding). The District plans to elevate the portables, but it has no solution for accessing the campus during flood days. At the June 10, 2024 Community Forum, the District consultant conceded, “You might not have an easy way to get to the school because all the streets will be flooded, but the school will be above that.” Not a great solution for parents trying to get their kids to school. Moreover, wading through that water could itself be dangerous, given the underlying toxic soil.
In an effort to cut costs the district is now looking to further eliminate decks between the temporary site trailers which were intended to keep the kids out of flood waters and reduce seawalls by 50% (see slide see slide 25 of the July 18, 2024 Board Meeting
Sewer Plant Smell Mitigation
What MVSD Wrote (Deck presented 9/11/23)
“Smells from Sewer Plant are Unpleasant.
[Considering] Indoor Air Circulation”
Our Lingering Concerns:
Indoor air circulation is helpful, but not sufficient to address time spent outdoors, in the stench, between classes, at recess, and at lunch.
At the December 2023 Community Forum, a District consultant explained that the portables will have “mechanical ventilation that takes advantage of outside air, but has some controls on it for Smoke Days, or in the case of this location, Smell Days from the sewer treatment plant.” Every day is a Smell Day at the proposed temporary site. The temporary site is far more pungent than the current MVMS site, due to more direct proximity to the sewer plant and the direction of prevailing winds.
Soil Mitigation
What MVSD Wrote (Deck presented 9/11/23)
“Possible land fill such as refuse, rubble, or man-made debris at Mill Valley MS site
Presence of groundwater and bay mud
Preliminary investigation has identified potential for Liquefaction and corrosion at Mill Valley MS site (Based on 2018 Geotechnical Report)
Possible soil improvements and/or deep foundations required
Detailed Geotechnical investigation will be done once site is selected.”
Our Lingering Concerns
MVSD is minimizing the extent of the soil hazard by referring to it as “Possible land fill” when it is undeniably landfill with elevated toxic substances, as documented by various historical records, photos, and even MVSD reports going back decades!
The workers will be wearing hazmat gear, but the kids will not. Moreover, the kids will not have training, or a clear path, to evacuate fast enough in the event a methane or other toxic substance alarm sounds. Methane accidents happen quickly and can be tragic.
Deep foundations will certainly be required due to marshland and seismic liquefaction zone, but placing deep foundations will necessarily penetrate the soil cap and bring hazardous materials to the surface and into the air, while our children will be located next door.
Yes, there needs to be a detailed Geotechnical investigation, but this must be done BEFORE selecting a site, not once one is selected! A review of existing Geotechnical reports already shows potentially explosive methane gas and high levels of lead, which should give MVSD pause, especially for the temporary site.
Our District has only budgeted $7.8 million for soil mitigation. If our District, like SDUSD, has to remove all the toxic soils at the current site, it will likely be much more than $33 million. This is a material budget concern, and the District needs to do soil samples and talk to DTSE about this as soon as possible, to avoid wasting bond funds in furtherance of a project that may not be economically viable as presently planned. The District received the following from DTSE on July 25, 2024, DTSE Comments on NOP. The DTSE warns, “we recommend the District consider that conservative remedial option may be necessary for evaluation in the EIR.” Also sobering to read, “DTSE believes that piers were likely used to support the current school building foundations. These foundation piers…[create] a preferential pathway for landfill leachate to infiltrate the groundwater.” The statement about a “conservative remedial option” is telling because DTSE recently insisted on complete soil removal at Noah Webster in San Diego. DTSE said that SDUSD could either leave the soil cap intact and put in place monitoring of the landfill materials, or it would have to remove all the soil. The situation at SDUSD is still unfolding, but here’s the latest DTSE letter about it, from Feb 13, 2024, where they say the soil has to come out. The environmental consultant managing that project is the same one our District has hired (Ninyo and Moore).
For more perspective on mitigation measures, let’s look to a report from the 1980s that described the remedial plan for the construction of the Ryan Creek pump station (behind MVMS, along the creek, near proposed temporary campus). Key excerpts:
“[B]ased on previous testing of soil…much of the removed soil will be hazardous waste due to levels of lead and zinc above Total Threshold Limit Concentrations (TTLC).”
“The possible hazards on this job are expected to be: Physical hazards including broken glass and scrap metal that may be present in the soil. Chemical hazards from elevated levels of lead and zinc in the soil….All personnel participating in the field must be trained in the general and specific hazards unique to the job and, if applicable, meet recommended medical requirements.”
Workers are advised to “Wash hands before eating or drinking.” and “Keep dust to a minimum, avoid breathing dust as much as possible.”
Under “Personnel Decontamination” the mitigation plan advises: “Wash boots. Launder coveralls at commercial laundry. Dispose of work gloves daily. Wash hands and face as soon as possible after stopping work.”
None of those mitigation measures are feasible at a school!
Kids lack training or even awareness of the risks. They will inevitably eat and touch their faces without perfect hand washing. They will exercise and eat without OSHA masks. Parents are surely not going to wash all those shoes and clothes regularly in a commercial laundry! If this is what was required for this site in the 1980s, imagine what extra mitigation steps will be required today. It is just not possible for children to protect themselves without training and personal protective equipment, which is, of course, absurdly unrealistic.
Moreover, MVSD is asking us to trust them with this when, just a few months ago, it received a Notice of Violation providing, “Site is not being maintained in a manner which protects public health and safety or prevents public contact with waste.”