2025-06_RAP Approval_BF00030011 MINNESOTA POLLUTION
CONTROL AGENCY
520 Lafayette Road North I St. Paul, Minnesota 55155-4194 1 651-296-6300
800-657-3864 1 Use your preferred relay service I info.pca@state.mn.us I Equal Opportunity Employer
June 16, 2025
VIA EMAIL
Kevin Nestingen
Kwik Trip Incorporated
1626 Oak St
La Crosse, WI 54603-2308
RE: Approval of Response Action Plan/Construction Contingency Plan
Kwik Trip 1795, 4160, 4168 and 4198 Pilot Knob Road, Eagan
MPCA Site ID: BF0003001
Billing ID: 112533
PINS: 103310001010, 103310001020, and 103310001032
Dear Kevin Nestingen:
The Minnesota Pollution Control Agency (MPCA) staff in the Voluntary Investigation and Cleanup (VIC)
Programs has reviewed the Response Action Plan/ Construction Contingency Plan (RAP/CCP) submitted
for the Kwik Trip 1795 site, located at the address referenced above (the Site). The RAP/CCP dated May
13, 2023, was prepared and submitted on your behalf by Braun Intertec Corporation.
The 3.53 -acre Site consists of three contiguous parcels that are currently developed with two multi -
tenant, strip -mall style retail buildings. Historically the Site was vacant or agricultural land until the early
1980s when the existing retail buildings were constructed, followed by construction of a filling station in
the southern portion in 1990. Previous occupants of the retail buildings included a restaurant, gift shop,
insurance office, convenience store, learning center, dry cleaner, liquor store, and dental and
chiropractic offices. Dry cleaner businesses occupied a portion of the retail building on the northwest
portion of the Site from approximately 1980 to 2015. The northwest building is currently vacant (4160
address) and the northeast retail building is occupied by office space and a liquor store (4168 address).
The former southern building was used as a filling station until it was demolished, and the associated
underground storage tanks were removed in 2022 (4198 address). Kwik Trip Incorporated intends to
demolish the remining buildings and redevelop the Site with a filling station and convenience store.
A sub -slab soil vapor investigation in 2016 identified tetrachloroethene (PCE) greater than action levels
beneath the former dry cleaning tenant space in the northwest building. The property that makes up the
northwest building (4160-4166 Pilot Knob Road) was enrolled in the Superfund Program as a non -listed
site (Martinizing Dry Cleaning, SR0001433) in December 2016. An active sub -slab depressurization
system (SSDS) was installed to mitigate vapors beneath the building in 2017 and is still operating in the
vacant northwest building.
Additional environmental investigations were completed at the Site in 2020, 2024, and 2025. In
February, July, and December 2020 a total of 17 soil samples were collected from 14 borings and
analyzed for volatile organic compounds (VOCs), diesel range organics (DRO), and gasoline range
organics (GRO). One groundwater sample was collected from a temporary monitoring well in the
northwestern area of the Site and analyzed for VOCs, DRO, and GRO. No VOCs were detected above
reporting limits (RLs) in the soil samples or groundwater sample.
t-rem-vic2-15 • LB 1537 • 5113122
Kevin Nestingen
Page 2
June 16, 2025
A total of 10 soil borings (8 shallow, 2 deep) were advanced at the Site in August 2024. Soil borings
identified historical fill intermixed with debris to depths up to 8.5 feet below ground surface. Ten soil
samples were collected from the borings and analyzed for VOCs. No VOCs were detected in the soil
samples. Ten groundwater samples were collected at the Site from temporary monitoring wells and
analyzed for VOCs. Tetra ch loroethene was detected in groundwater at concentrations less than its
Health Risk Limit (HRL) established by the Minnesota Department of Health (MDH) for drinking water
purposes.
Nine exterior and six sub -slab soil vapor samples were collected at the Site in February 2020 and
December 2020 (heating season) and June 2020 (non -heating season). The sub -slab soil vapor samples
were collected beneath the unmitigated northeast building at the Site. One exterior soil vapor sample
collected from the southeastern area of the Site detected PCE and trichloroethylene (TCE) at
concentrations greater than thirty-three times (33X) their commercial intrusion screening values (ISVs).
However, review of laboratory quality assurance data indicated the sample was cross contaminated
from a previous sampling event. Two confirmation soil vapor samples were collected from the same
area as the elevated PCE/TCE sample. Trichloroethene was not detected and PCE was detected at less
than its commercial ISV in the two confirmation samples. Five exterior soil vapor samples were collected
in the footprint of the proposed convenience store at the Site in August 2024 (non -heating season) and
January 2025 (heating season). Tetrachloroethene was detected in soil vapor at concentrations less than
its commercial ISV.
The RAP/CCP proposes environmental monitoring and soil characterization in the former drycleaner
area after demolition of the northern buildings, and proper management and disposal of contaminated
soil encountered during construction activities. The RAP/CCP is approved, subject to the following
conditions/clarifications:
1. This approval excludes contingency/response actions related to petroleum compounds at the
Site. Technical assistance for petroleum can be requested from the MPCA's Petroleum
Brownfield Program.
2. The 55 -gallon drums in the former dry cleaner tenant space shall be characterized and properly
disposed of prior to building demolition.
3. Excavations within the former dry cleaner area should meet the soil leaching values (SLVs) for
PCE; the depth of the excavation need not extend beyond the depth to perched groundwater.
Dry cleaning solvent source areas encountered during excavation that appear to extend beyond
the planned excavation area should be removed to the groundwater table or four feet below
ground surface (bgs) (whichever is encountered first) and to meet SLVs.
4. Soil from the former dry cleaner tenant space area shall be characterized with laboratory
analysis to determine suitability for on-site reuse (if applicable). Otherwise, the soil excavated
from this area shall not be reused and shall be disposed of at a permitted landfill.
5. A soil buffer meeting commercial SRVs shall be established in all greenspace areas (four feet)
and below new pavement/buildings (two feet).
6. Backfill within utility trenches at the Site shall be free of VOCs/elevated organic vapors and meet
MPCA's commercial SRVs.
7. Confirmation soil samples shall be collected for laboratory analyses of contaminants of concern
from the base and sidewalls of excavations in the area of the former drycleaner, and other areas
where field observations indicate contamination may exist. Please refer to MPCA sampling
guidance for the recommended number of confirmation samples based on the size of the
excavation.
Kevin Nestingen
Page 3
June 16, 2025
8. Imported soil and excess fill targeted for off-site reuse shall be from a native source and/or
meet the MPCA's criteria for unregulated fill. Soils that do not meet unregulated fill criteria may
not be used at the discretion of the contractor or other project personnel.
9. Any contaminated soils removed from the Site must be treated or disposed of in a method
approved by the MPCA. Contaminated soils transported to an approved landfill must comply
with all state and local permits. Please include all transportation and handling manifests for such
soils in the final implementation report.
10. This RAP/CCP approval is contingent on the applicant obtaining all other required state, federal,
and local government permits.
11. The MPCA Brownfield Program staff does not review or approve dewatering actions, including
the testing, discharge and/or treatment of groundwater, stormwater, or any other dewatering
action.
12. Depending on final Site conditions, as documented in the pending implementation report, an
institutional control may be required prior to the MPCA issuing closure letter(s) for the Site. The
need for and type of institutional control will be determined after MPCA review of the
implementation report.
An implementation report describing the completed response actions, sampling results, soil
management and disposal, and imported soils shall be prepared and submitted to the MPCA. If the
implementation report will not be submitted within one year of the date of this letter, please notify the
MPCA project staff of the status of the project.
Approval of this plan does not suggest that any of the costs incurred will be eligible for reimbursement
from the Drycleaner Fund. This letter is subject to the disclaimers found in Attachment A. If you have
any questions about this letter, please contact Rebecca Ryser, Project Manager, at 651-757-2015 or by
email at rebecca.rvser@state.mn.us.
Sincerely,
This document has been electronically signed.
Rebecca Ryser
Hydrologist
Remediation Division
RJR:df
Attachment
cc: Nicholas Stingl, Braun Intertec Corporation (electronic) (w/attachment)
Elizabeth VanHoose, City of Eagan (electronic) (w/attachment)
Nikki Stewart, Dakota County Environmental (electronic) (w/attachment)
Disclaimers
Kwik Trip 1795
MPCA Site ID: BF0003001
1. Reservation of authorities
Attachment A
The Minnesota Pollution Control Agency (MPCA) Commissioner reserves the authority to take any
appropriate actions with respect to any release, threatened release, or other conditions at the Site.
The MPCA Commissioner also reserves the authority to take such actions if the voluntary party does
not proceed in the manner described in this letter or if actions taken or omitted by the voluntary
party with respect to the Site contribute to any release or threatened release or create an imminent
and substantial danger to public health and welfare.
2. No MPCA assumption of liability
The MPCA, its Commissioner, and staff do not assume any liability for any release, threatened
release, or other conditions at the Site or for any actions taken or omitted by the voluntary party
with regard to the release, threatened release, or other conditions at the Site, whether the actions
taken or omitted are in accordance with this letter or otherwise.
3. Letter based on current information
All statements, conclusions, and representations in this letter are based upon information known to
the MPCA Commissioner and staff at the time this letter was issued. The MPCA Commissioner and
staff reserve the authority to modify or rescind any such statement, conclusion, or representation
and to take any appropriate action under the Commissioner's authority if the MPCA Commissioner
or staff acquires information after issuance of this letter that provides a basis for such modification
or action.
4. Disclaimer regarding use or development of the property
The MPCA, its Commissioner, and staff do not warrant that the Site is suitable or appropriate for any
particular use.
5. Disclaimer regarding investigative or response action at the property
Nothing in this letter is intended to authorize any response action under Minn. Stat. § 1156.17,
subd. 12.
6. This approval does not supplant any applicable state or local stormwater permits, ordinances, or
other regulatory documents.
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