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.
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.
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!
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 from the Superfund site 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.
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.”