MN Pollution Control Agency - 4601 Shoreline Drive - 8/11/2026
t-rem-vic2-16 · LB 1533 · 5/16/22
August 12, 2026
Michael Piehler
Parkshore Apartments MN, LLC
821 Raymond Ave Ste 400
Saint Paul, MN 55114-1525
RE: Retroactive No Association Determination for Past Actions
No Association Determination for Proposed Actions
Parkshore Apartments, 4601 Shoreline Drive, Spring Park
MPCA Site ID: BF0003255
MPCA Billing ID: 266287
PINs: 18-117-23-33-0061, 18-117-23-33-0062, and 18-117-23-34-0247
Dear Michael Piehler:
This letter is in response to the request from Danny Margarit of Carlson McCain, LLC for a determination
under Minn. Stat. § 115B.178, subd. 1(b), that certain past actions taken by Parkshore Apartments MN,
LLC at the Parkshore Apartments site, located at the address referenced above (the Site), did not
constitute conduct that would associate Parkshore Apartments MN, LLC with the release or threatened
release of hazardous substances, pollutants, or contaminants at the Site for the purpose of Minn. Stat. §
115B.03, subd. 3(a)(4).
The Minnesota Pollution Control Agency (MPCA) staff in the Voluntary Investigation and Cleanup (VIC)
Program has reviewed the documents submitted for the Site. The Site includes three parcels developed
with three apartment buildings, two garage structures, a pool, and a pool equipment building. The Site
was historically developed with a single-family residence until redevelopment with the existing apartment
buildings in 1969 and 1984. Parkshore Apartments MN, LLC purchased the Site on December 19, 2025, and
intends to continue leasing the existing apartment buildings to residential tenants.
A limited environmental investigation was completed at the Site in January 2026. Two soil samples were
collected and analyzed for volatile organic compounds (VOCs). No VOCs were detected in soil samples
except for acetone, which is a common laboratory contaminant. One groundwater sample was collected
at the Site from a temporary monitoring well and analyzed for VOCs. Acetone and 2‐Butanone (MEK),
another common laboratory contaminant, were detected in the groundwater sample. The MPCA does
not consider the detections of acetone or MEK in soil or groundwater to reflect a confirmed release.
There were no other detections above laboratory reporting limits for other VOCs.
Michael Piehler
Page 2
August 12, 2026
Twelve sub-slab soil vapor samples were collected at the Site (six in the northern apartment building
and six in the southern apartment building) in December 2025 (heating season) and April 2026 (non-
heating season). Tetrachloroethene (PCE) was detected in sub-slab soil vapor at concentrations less
than the MPCA action level of 33X the residential ISV. Trichloroethene (TCE) was detected in sub-
slab soil vapor at concentrations less than the residential ISV.
Four exterior soil vapor samples were collected at the Site in January 2026 (heating season) and April
2026 (non-heating season). Only 1,3-butadiene was detected in soil vapor at a concentration greater
than the MPCA action level of thirty-three times (33X) its residential intrusion screening value (ISV).
1,3-butadiene is commonly found in soil vapor in urban environments due to its association with
petroleum products, vehicle exhaust, and asphalt. It is unlikely that the 1,3-butadiene stems from a
release of hazardous substances at the Site. Neither PCE nor TCE were detected in the exterior soil vapor
samples.
For the purpose of this letter, the identified release consists of PCE and TCE in soil vapor (Identified
Release). This letter does not address petroleum-related contaminants. Petroleum contamination
detected at the Site is under the oversight of the MPCA’s Petroleum Brownfield Program.
Based upon a review of the information provided to the MPCA VIC Program, and subject to the
conditions set forth in this letter, a determination is hereby made pursuant to Minn. Stat. § 115B.178,
subd. 1(b) that the past actions (Past Actions) as described below and as described in the Affidavit of
Michael Piehler dated May 18, 2026 (Affidavit) will not associate Parkshore Apartments MN, LLC with
the Identified Release for the purpose of Minn. Stat. § 115B.03, subd. 3(a)(4). This determination is
being sought for Parkshore Apartments MN, LLC and the determination is retroactive to the date that
Parkshore Apartments MN, LLC purchased the Site. This determination applies to the following Past
Actions:
• Purchase of the Site
• Leasing the Site to residential tenants
• Operation and maintenance of the Site building, grounds, and related infrastructure
This letter also addresses Parkshore Apartments MN, LLC’s request for a determination under Minn.
Stat. § 115B.178, subd. 1(a) that certain actions proposed to be taken by Parkshore Apartments MN, LLC
at the Site will not constitute conduct associating Parkshore Apartments MN, LLC with the release or
threatened release of hazardous substances, contaminants, or pollutants at the Site for the purposes of
Minn. Stat. § 115B.03, subd. 3(a)(4).
Based upon a review of the information provided to the MPCA VIC Program, and subject to the
conditions set forth in this letter, a determination is hereby made pursuant to Minn. Stat. § 115B.178,
subd. 1(a) that the proposed actions (Proposed Actions) as described below will not associate Parkshore
Apartments MN, LLC with the Identified Release for the purpose of Minn. Stat. § 115B.03, subd. 3(a)(4).
This determination applies to the following Proposed Actions:
• Leasing the Site to residential tenants
• Operation and maintenance of the Site building, grounds, and related infrastructure.
Michael Piehler
Page 3
August 12, 2026
The Retroactive No Association Determination and No Association Determination made in this letter are
subject to the following conditions:
1. The representations made in the Affidavit are accurate and the Past Actions were carried out as
described herein and in the Affidavit.
2. The Proposed Actions shall be carried out as described herein.
3. Parkshore Apartments MN, LLC shall cooperate with the MPCA, its employees, contractors, and
others acting at the MPCA’s direction, in the event that the MPCA takes, or directs others to
take, response actions at the Site to address the Identified Release or any other as yet
unidentified release or threatened release of a hazardous substance, pollutant, or contaminant,
including, but not limited to, granting access to the Site so that response actions can be taken.
4. Parkshore Apartments MN, LLC shall avoid actions that contribute to the Identified Release or
that interfere with response actions required under any MPCA-approved response action plan
to address the Identified Release.
Pursuant to Minn. Stat. § 115B.178, subd.1, when Parkshore Apartments MN, LLC takes the Proposed
Actions in accordance with the determination in this letter, subject to the conditions stated herein, the
Proposed Actions will not associate Parkshore Apartments MN, LLC with the Identified Release for the
purpose of Minn. Stat. § 115B.03, subd. 3(a)(4).
Please be advised that the determination made in this letter is subject to the disclaimers found in
Attachment A and is contingent on compliance with the terms and conditions set forth herein.
If you have any questions about the contents of this letter, please contact Victoria Jolly, Project
Manager, at 651-757-2098 or by email at victoria.jolly@state.mn.us.
Sincerely,
Amy K. Hadiaris
This document has been electronically signed.
Amy K. Hadiaris, P.G.
Supervisor
Voluntary Investigation and Cleanup Unit
Remediation Division
AKH/VJ:mh
Enclosure/Attachment
cc: Jamie Hoffman, Spring Lake City Clerk (electronic) (w/attachment)
Mary Finch, Hennepin County (electronic) (w/attachment)
John Lichter, Carlson McCain, LLC (electronic) (w/attachment)
Attachment A
Page 1 of 1
Disclaimers
Parkshore Apartments
MPCA Site ID: BF0003255
1. Reservation of authorities
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. § 115B.17,
subd. 12.
6. This approval does not supplant any applicable state or local stormwater permits, ordinances, or
other regulatory documents.