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26-398 Analysis of Brownfields Cleanup Alternatives

Fresno City Council
May 7, 2026

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26-398 Analysis of Brownfields Cleanup Alternatives
Meeting
May 7, 2026
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Fresno City Council
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11
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Text extracted from the city's file for reading and search. Open the original on legistar2.granicus.com. That file is the official record.

ANALYSIS OF BROWNFIELD CLEANUP

ALTERNATIVES
Former Berkeley Building
887 Fulton Street
Fresno, California 93721
December 5, 2025
Prepared for:

City of Fresno
2600 Fresno Street, Room 3076
Fresno, California 99201
Prepared by:

Stantec Consulting Services Inc.
601 SW 2nd Avenue, Suite 1400
Portland, Oregon 97204
Project Number: 203724380
USEPA Brownfields Revolving Loan Fund
Grant
Agreement No. 4B98T50501
Property ID: 266678

This document entitled Analysis of Brownfield Cleanup Alternatives – Former Berkeley Building, 887 Fulton Street, Fresno, California 93721 was prepared by Stantec Consulting Services Inc. (“Stantec”) for the account of the City of Fresno (the “Client”). Any reliance on this document by any third party is strictly prohibited. The material in it reflects Stantec’s professional judgment in light of the scope, schedule and other limitations stated in the document and in the contract between Stantec and the Client.

The opinions in the document are based on conditions and information existing at the time the document was published and do not take into account any subsequent changes. In preparing the document, Stantec did not verify information supplied to it by others. Any use which a third party makes of this document is the responsibility of such third party. Such third party agrees that Stantec shall not be responsible for costs or damages of any kind, if any, suffered by it or any other third party as a result of decisions made or actions taken based on this document.

Prepared by
_____
(signature)
Kristin Stout
Reviewed by
________
(signature)
David Holmes
Reviewed by _______
(signature)
Graeme Taylor, Project Manager

Table of Contents
1 INTRODUCTION.............................................................................................................. 1

1.1 Subject Property Location and Description.................................................................................. 1

1.2 Subject Property History.............................................................................................................. 1 2 REGULATED BUILDING MATERIALS RESULTS SUMMARY .................................... 2

2.1 Asbestos Containing Materials Findings...................................................................................... 2

2.2 Lead-Based Paint Findings.......................................................................................................... 4

2.3 Inventory of Materials Requiring Special Handling ...................................................................... 4 3 APPLICABLE REGULATIONS AND CLEANUP STANDARDS ................................... 5

3.1 Cleanup Oversight Responsibility................................................................................................ 5

3.2 Applicable Cleanup Standards for Key Contaminants................................................................. 5

3.3 Laws and Regulations Applicable to Cleanup.............................................................................. 5 4 EVALUATION OF CLEANUP ALTERNATIVES ............................................................ 7

4.1 Remedial Action Objective........................................................................................................... 7

4.1.1 Asbestos-Containing Materials, Lead Based Paint, and Mold ..................................................... 7

4.2 Cleanup Alternatives Considered ................................................................................................ 7

4.2.1 Alternative 1: No Abatement Alternative...................................................................................... 7

4.2.2 Alternative 2: Encapsulation/Enclosure ....................................................................................... 8

4.2.3 Alternative 3: Complete Abatement of ACM/LBP/Mold – Roof Repair/Replacement................... 8

4.3 Cleanup Alternative Evaluation.................................................................................................... 9

4.3.1 Effectiveness ............................................................................................................................... 9

4.3.2 Ability to Implement ................................................................................................................... 10

4.3.3 Costs ......................................................................................................................................... 11

4.3.4 Green Remediation Considerations........................................................................................... 12

4.4 Recommended Cleanup Alternative.......................................................................................... 13 5 REFERENCES ................................................................................................................. 1 LIST OF TABLES:

Table 2.1: Asbestos Containing Materials and Locations
Table 2.2: Lead Paint Samples and Locations
FIGURES:

FIGURE 1 – SUBJECT PROPERTY LOCATION MAP
FIGURE 2 – SUBJECT PROPERTY PROJECT AREA MAP

LIST OF APPENDICES

APPENDIX A PROPOSED BUILDING RENOVATION PLANS

APPENDIX B UNDATED PROPERTY FLOOR PLAN

APPENDIX C R EGULATED BUILDING MATERIALS SURVEY REPORTS APPENDIX D COST ESTIMATE FOR ALTERNATIVES 2 AND 3
Project Number: 203724380 i

Analysis of Brownfield Cleanup Alternatives
1 Introduction
December 5, 2025
1 Introduction
This Analysis of Brownfield Cleanup Alternatives (ABCA) was prepared for the City of Fresno for the Berkeley Building property located at 887 Fulton Street, Fresno, California 93721 (the “Subject Property”).

The purpose of the ABCA is to present options and costs for the abatement of regulated building materials (RBM) (i.e. ., asbestos -containing materials [ACM] and lead- based paint [LBP]) identified during the completion of an Asbestos Survey and Lead Based Paint Survey on behalf of the Fresno Area Hispanic Foundation on October 29, 2024 and July 22, 2025, respectively. The redevelopment plans for the 0.26- acre Subject Property includes repair and renovation of the existing building as necessary for planned use for commercial retail space, office space and as a community center. The second floor will be used as offices for small businesses and entrepreneurs. A draft proposed building renovation plan is included in Appendix A.

1.1 Subject Property Location and Description
The Subject Property is comprised of a 0.26-acre parcel identified by Fresno County Assessor Parcel Number (APN) 468-282-21T. The parcel owner is listed as the Successor Agency to the Redevelopment Agency who has a Disposition and Development Agreement with the Fresno Area Hispanic Foundation .

The Subject Property is occupied by a vacant two-story former commercial department store building.

Adjacent properties are a mix of commercial buildings, vacant land, a park, and railroad tracks and spurs.

A Subject Property location map is provided as Figure 1. A Subject Property area map illustrating the main features of the Subject Property is provided as Figure 2.

1.2 Subject Property History
In July 2024, Krazan & Associates, Inc. (Krazan) completed a Phase I environmental site assessment (ESA) to document environmental conditions on the Subject Property (Krazan, 2024). Krazan reported that t he Subject Property was first developed during or prior to 1898 as a blacksmith, machine shop, and lodging.

By 1906, the Subject Property was occupied by a machine works building, a woodworking building, and a building labeled “agricultural implements .” By 1918, the Subject Property was occupied by a printing machine shop, a machine shop, five stores, a restaurant, and other enterprises. By 1948, the Subject Property was occupied by five stores, a dancing school, a furniture facility, a storage facility, and an electric shop. The present -day building was constructed in the early 1960s as a department store (the Former Berkeley’s Department Store) but has mostly been vacant since 1982. An undated floor plan of the building from its time as a department store including the basement, 1 st floor, and 2nd floor is included in Appendix B. At the time of the Phase I ESA reconnaissance, the Subject Property building was not in use.

Project Number: 203724380 1

Analysis of Brownfield Cleanup Alternatives
2 REGULATED BUILDING MATERIALS RESULTS SUMMARY
December 5, 2025
2 REGULATED BUILDING MATERIALS RESULTS SUMMARY
On October 29, 2024 and July 22, 2025, an Asbestos Survey and Lead-Based Paint Survey were completed by Krazan on behalf of the Fresno Area Hispanic Foundation. Sampling for t he Asbestos Survey was completed at the Subject Property on October 14, 2024, and included the collection of 62 samples of suspect ACM materials. Sampling for the Lead-Based Paint Survey was completed on July 10, 2025, and included the collection of 31 paint samples. Copies of both reports are included in Appendix C.

2.1 Asbestos Containing Materials Findings
Suspect ACM materials identified during the onsite survey conducted by Krazan were grouped and classified as homogeneous materials based on their appearance, usage, and age of the building.

Representative samples of each homogeneous material were sampled in accordance with federal regulations. ACM was identified in 17 of the 62 samples collected, including the following materials:
• Texture
• 9x9 floor tile and mastic
• Sheet vinyl flooring and mastic
• Pipe elbow
• Roof core
• Roof mastic
• Vent pipe (assumed)
ACM was detected in trace amounts in the following:
• Gypsum board / taping material
No ACM was detected in the following materials:
• Plaster
• Skim coat
• Wallpaper
• 12x12 ceiling tile
• 2x4 ceiling panel
• Stair tread
Project Number: 203724380 2

Analysis of Brownfield Cleanup Alternatives
2 REGULATED BUILDING MATERIALS RESULTS SUMMARY
December 5, 2025
• Ceiling tile mastic
• Base cove mastic
• Paneling mastic
• Ducting tape
• Pipe insulation wrap
• Stucco
• Roof tar
• Terrazzo flooring
Table 2. 1 below presents a sample number, material description, sample location, the ACM content, material condition and estimated quantity of the material.

Table 2.1: Asbestos Containing Materials and Locations
SAMPLE

NUMBER MATERIAL DESCRIPTION SAMPLE

LOCATION ASBESTOS CONTENT CONDITIONQUANTITY
8 Gypsum Board / taping material 2nd Floor Trace NA 60,000 SF 9 Gypsum Board / taping material 2nd Floor Trace NA See #8 10 Gypsum Board / taping material 1st Floor Trace NA See #8 11 Gypsum Board / taping material 1st Floor Trace NA See #8 12 Gypsum Board / taping material Basement Trace NA See #8 13 Gypsum Board / taping material Basement Trace NA See #8 14 Texture 2nd Floor 4% Good / Friable 60,000 SF
15 Texture 2nd Floor 4% Good / Friable See #14
16 Texture 1st Floor 4% Good / Friable See #14
17 Texture 1st Floor 4% Good / Friable See #14
18 Texture Basement 4% Good / Friable See #14
19 Texture Basement 4% Good / Friable See #14
33 Brown Streaked 9-in by 9-in Floor tile /
mastic 2nd Floor 4% / 4% Good / NF 600 SF
34 Gray Streaked 9-in by 9-in Floor tile /
mastic 2nd Floor 5% / 4% Good / NF 450 SF
35 Tan 9-in by 9-in Floor tile 2nd Floor 6% Good / NF 700 SF 36 Tan 9-in by 9-in Floor tile / mastic 2nd Floor 5% / 4% Good / NF 75 SF 37 Brown Streaked 9-in by 9-in Floor tile /
mastic 1st Floor 4% / 4% Good / NF 600 SF
39 Tan 9-in by 9-in Floor tile / mastic Basement 4% / 4% Good / NF 800 SF 40 Green Streaked 9-in by 9-in Floor tile /
mastic Basement 4% / 5% Good / NF 300 SF
49 Pipe elbow Basement 8% Good / NF <50 SF
55 Roof core Roof 15% Good / NF 11,000 SF
60 Roof mastic Roof 8% Good / NF <100 SF
62 Brown Streaked 9-in by 9-in Floor tile /
mastic 2nd Floor 4% / 4% Good / NF 200 SF
- Vent pipe Basement Assumed Good / NF 75 SF
Project Number: 203724380 3

Analysis of Brownfield Cleanup Alternatives
2 REGULATED BUILDING MATERIALS RESULTS SUMMARY
December 5, 2025
Notes and Abbreviations:

SF = Square Feet; NF = Non Friable
Previously undiscovered asbestos may be present within wall cavities (e.g., asbestos in electrical wire wrapping, insulation materials, vapor barrier paper, etc.), and some underground utility piping has been known to contain asbestos (e.g., transite pipe). If discovered during abatement or renovation, suspect ACMs that are not identified within this report will be assumed positive for asbestos unless additional sampling, analysis, and/or assessment indicates otherwise.

2.2 Lead-Based Paint Findings
The lead-based paint survey consisted of a visual inspection and sampling of painted surfaces throughout the two floors of the building on the Subject Property. The purpose of the inspection was to provide information regarding lead in paint as it pertains to employee exposure and demolition debris disposal.

Representative samples of the painted surfaces were collected by Krazan for laboratory analysis. Additional suspect painted surfaces may be present in areas that were inaccessible, unsafe to inspect, or obscured from view during the sampling process. Two of the 31 collected samples contained lead greater than 0.5% (the EPA definition of a lead-based paint) as shown in Table 2.2 below.

Table 2.2: Lead Paint Samples and Locations
SAMPLE

NUMBER COLOR BUILDING

COMPONENT SUBSTRATE SAMPLE

LOCATION
SQUARE
FEET

LEAD CONTENT
%
4 Pink Wall Gypsum Board 2nd Floor 400 0.74
20 Pink Partition Wall Wood 1ST Floor 200 1.3

2.3 Inventory of Materials Requiring Special Handling
A mold survey was not prepared for the Subject Property; however, openings in the roof and visible mold were observed throughout the Subject Property. There is significant mold and anticipated water damage throughout the building’s interior. These materials will require special handling to limit exposure to workers and release to other surfaces. ACMs which have been found in roofing materials (roof core and the roof mastic) and other materials as discussed in Section 2.1. The roof is partially deteriorated and fall en fragments are located throughout the building interior on the floor and on various surfaces where there is also mold present. Therefore, the mold is considered to be comingled with identified ACMs and LBP.

Materials to be removed from the building will require special handling for mold, LBP and ACMs and will therefore be managed as asbestos-containing waste materials (ACWMs), unless determined otherwise by sampling.

Project Number: 203724380 4

Analysis of Brownfield Cleanup Alternatives
3 APPLICABLE REGULATIONS AND CLEANUP STANDARDS
December 5, 2025
3 APPLICABLE REGULATIONS AND CLEANUP STANDARDS

3.1 Cleanup Oversight Responsibility
Subject Property cleanup and redevelopment should be conducted in compliance with applicable laws, regulations, and procedures outlined below.

3.2 Applicable Cleanup Standards for Key Contaminants
Cleanup standards for key contaminants at the Subject Property include the following:

Asbestos – Cleanup standard for asbestos are based on the USEPA Asbestos -Containing Materials in Schools, Final Rule and Notice (USEPA, 1987). Although this rule is in place primarily to protect child - occupied facilities, following the guidelines within the rule is encouraged for all building renovations for the overall protection of human health.

LBP – Building materials containing lead in paint or other surface coating material containing lead are defined by the U.S. Department of Housing and Urban Development (HUD) and USEPA as greater than or equal to 5,000 parts per million or 0.5% by weight (HUD, 1997). The cleanup standards are assumed to equal this level.

Mold – The California Department of Public Health (CDPH) does not recommend performing testing for mold, and notes in their frequently asked questions guidance that the focus for mold should be on identifying and addressing sources of moisture that are generally responsible for the growth of mold. There are no specific cleanup standards for mold linked to mold counts or specific species of mold.

3.3 Laws and Regulations Applicable to Cleanup
This section is provided for informational purposes only and the property owner (or contractor implementing the cleanup) is responsible for ensuring compliance with all applicable laws and regulations.

Cleanup activities at the Subject Property should be conducted by contractors operating in accordance with the U.S. Department of Labor Occupational Safety & Health Administration (OSHA) Hazardous Waste Operations and Emergency Response (HAZWOPER) standard codified at 29 Code of Federal Regulations 1910.120. The HAZWOPER standard applies to cleanup operations required by federal, state, local, or other governmental bodies involving hazardous substances. Additionally, the California OSHA “Lead in Construction Standard” codified in Title 8 California Code of Regulations Section 1532.1, is applicable to construction work where an employee may be exposed to lead.

National Emission Standards for Hazardous Air Pollutants (NESHAP) are outlined in the Code of Federal Regulations (CFR) Title 40 Chapter I Subchapter C Part 61 Subpart M. OSHA regulations regarding asbestos exposure during construction activities (i.e., renovation and demolition) are outlined in CFR Title 29 Subtitle B Chapter XVII Part 1926.1101, whereas OSHA regulations regarding respiratory protection are outlined in CFR Title 29 Subtitle B Chapter XVII Part 1910.134. A NESHAP notification form must be Project Number: 203724380 5

Analysis of Brownfield Cleanup Alternatives
3 APPLICABLE REGULATIONS AND CLEANUP STANDARDS
December 5, 2025
submitted at least 10 working days prior to the beginning of renovation or demolition activities involving ACMs. This notification form must include information regarding the company that performed the ACM survey, the analytical laboratory, the company performing the demolition or renovation activities, the company transporting waste that contains asbestos, and the landfill where the waste that contains asbestos will be disposed.

The Asbestos Hazard Emergency Response Act (AHERA) was designed to address the presence of asbestos in school buildings. AHERA also tasked the USEPA with developing a plan for accrediting individuals responsible for performing asbestos surveys and remediation. AHERA protocols are considered the best industry practice for asbestos surveys and remediation, and these protocols are typically applied to non -school buildings. Although no school buildings are located at the Subject Property, it is recommended that remediation be performed by a company that utilizes AHERA -certified personnel for asbestos demolition and remediation activities. AHERA is outlined in CFR Title 40 Chapter I Subchapter R Part 763 Subpart E.

Permitting for abatement of asbestos in Fresno County is subject to the requirements of the San Joaquin Valley Air Pollution Control District (SJVAPCD). Written notice must be submitted to the SJVAPCD at least 10 working days prior to beginning abatement. During removal, there are required emission control techniques and engineering controls to prevent asbestos fibers from becoming airborne. SJVAPCD will issue permit release forms certifying that the asbestos regulatory requirements have been met. The Subject Property owner and/or contractor are likely to be required to obtain these permit release forms before the local building or demolition permits can be granted
The USEPA has adopted the Renovation, Repair, and Painting (RRP) Rule (40 CFR 745.80) to minimize exposure from LBP dust by training contractors to make sure they follow lead -safe work practices during renovation of a structure. Although this rule is in place primarily to protect child-occupied facilities, following the guidelines within the rule is encouraged for all building renovations for the overall protection of human health. In addition to this rule, contractors are required to follow the HUD Lead Safe House Rule and all local and state specific requirements. The RRP Rule requires that renovators be USEPA -certified, accredited, and follow specific work practices.

The RRP Rule does not apply to the total demolition of structures. It is recommended that a certified lead inspector be on-site to oversee demolition activities and appropriate disposal of materials. Demolition work should be conducted by a lead-certified company trained to handle and dispose of LBP materials.

The Toxic Mold Protection Act of 2001 includes general provisions for disclosure of mold problems and for addressing mold as necessary to guarantee habitable conditions for tenants Federal laws and regulations applicable to this cleanup include the Small Business Liability Relief and Brownfields Revitalization Act and the Davis -Bacon Act. Federal, state, and local laws regarding procurement of contractors to conduct the cleanup are also applicable. Adherence to laws and regulations associated with abatement and removal of regulated building materials is the responsibility of individual contractors performing cleanup activities.

Project Number: 203724380 6

Analysis of Brownfield Cleanup Alternatives
4 EVALUATION OF CLEANUP ALTERNATIVES
December 5, 2025
4 EVALUATION OF CLEANUP ALTERNATIVES

4.1 Remedial Action Objective

4.1.1 ASBESTOS-CONTAINING MATERIALS, LEAD BASED PAINT, AND MOLD The Remedial Action Objective for ACMs and other hazardous materials at the Subject Property is to prevent these materials from causing unacceptable risk to human health and to allow the Subject Property to be reused as commercial retail space, office space, and a community center . The following formula is commonly used to represent risk:

RISK = EXPOSURE x CONCENTRATION
As indicated by this common formula, risk can be reduced by limiting exposure or by reducing the magnitude of contaminant concentration. The human exposure pathway of concern for ACMs is inhalation. ACM exposure can be limited by isolating ACMs from human contact or by maintaining ACMs in good condition so that asbestos fibers would not be released into indoor air where exposure via inhalation could occur.

The only way to reduce the ACM concentration is to abate the ACMs, which would reduce the concentration to zero. If the concentration is zero, then risk also would be zero.

4.2 Cleanup Alternatives Considered
Three alternatives were considered for the remedial action at the Subject Property : 1) No Abatement; 2) Encapsulation; and 3) Complete Abatement of ACMs. These three options are described below. The cost estimates presented in this document are based on quotes obtained from local vendors and based on professional judgement but should be independently verified and updated based on additional information identified during project implementation. A description of each alternative and the results of the comparative analysis are presented below.

4.2.1 ALTERNATIVE 1: NO ABATEMENT ALTERNATIVE
The No Action Alternative is included as a baseline for comparison to the other proposed alternatives. The No Action Alternative assumes that all ACM, LBP and mold within the building would remain in place.

Under this alternative, the owner must continue to secure the building to eliminate trespassing and also minimize uses of the building that require City employees and others to enter the building as it is considered a hazardous environment.

In order to prevent ACM releases to the exterior areas surrounding the Subject Property building, the building envelope must be maintained. Windows are the most obvious weak link in maintaining the building envelope. As a result, any broken windows should be addressed to maintain a secure building envelope.

This might include window replacement or using plywood to “board up” a broken window. This is particularly important if there are known ACMs in poor condition near a broken window.

Project Number: 203724380 7

Analysis of Brownfield Cleanup Alternatives
4 EVALUATION OF CLEANUP ALTERNATIVES
December 5, 2025
Roofing is a significant component of the building envelope and is known to contain ACM. Maintenance and repair will need to continue on the roof to ensure the building envelope does not fail and release ACM to the surrounding environment. The roof is already known to be in a state of disrepair and would need to be replaced or significantly repaired as a component of any redevelopment project. In addition to repair, tarps or other lightweight protective materials could be placed on the roof and weighed down to temporarily protect problem areas from the elements.

Lastly, under the No Abatement Alternative, the Subject Property owner must 1) limit access to the building interiors using security measures, including limiting access by authorized personnel, 2) ensure that the hazards of building entry are properly communicated to authorized personnel that may enter the buildings, and 3) establish an entry protocol for other authorized personnel that may enter the building.

4.2.2 ALTERNATIVE 2: ENCAPSULATION/ENCLOSURE
The encapsulation/enclosure alternative consists of the following activities:

1. Permitting and notifications for ACM, LBP and mold abatement activities.

2. Site preparation by establishing security fencing, drop boxes, decontamination areas, appropriate containment, barrier, and air -filtration systems and other work area preparations necessary for workers in appropriate protective clothing to work in areas subject to mold and ACM.

3. Completion of limited repairs to the roof (primarily focused on addressing the open holes in the roof).

4. Removing interior finishes to expose building structure without removing structural components (posts, beams, joists, etc.).

5. Cleaning and treating all accessible areas with mold using a microbial cleaning agent.

6. Encasing the existing ceiling with a new lower drywall ceiling.

7. Abating known ACM in other areas of the building (not including ACM materials in the ceiling or roof).

8. Disposing of waste at an appropriately licensed landfill under applicable waste manifests at a facility that can receive ACWM, LBP and mold-impacted building materials.

4.2.3 ALTERNATIVE 3: COMPLETE ABATEMENT OF ACM/LBP/MOLD – ROOF

REPAIR/REPLACEMENT
This complete abatement option consists of the following activities:

1. Permitting and notifications for ACM, LBP and mold abatement activities.

2. Site preparation by establishing security fencing, drop boxes, decontamination areas, appropriate containment, barrier, and air -filtration systems and other work area preparations necessary for workers in appropriate protective clothing to work in areas subject to mold and ACM.

Project Number: 203724380 8

Analysis of Brownfield Cleanup Alternatives
4 EVALUATION OF CLEANUP ALTERNATIVES
December 5, 2025

3. Repairing and/or replacing the roof as necessary to prevent further moisture intrusion through the roof on a long- term basis and enable mold abatement work on the interior of the building to be completed without risk of reoccurrence.

4. Establishing appropriate containment, barrier, and air -filtration systems as necessary for workers in appropriate protective clothing to work in areas subject to mold, LBP, and ACM.

5. Removing the ceiling and disposing of appropriately as ACWMs.

6. Restoration of the building may include repairing or rerouting any plumbing or water lines located in areas above the ceiling that are impacted by the ACM removal process and roof replacement. This is a requirement to restore the building envelope post abatement as these repaired utility lines would be located within the roofing/ceiling materials to service roofing equipment (heating, ventilation, and air conditioning [HVAC], emergency sprinkler systems, and water supply lines) as necessitated by a building restoration plan.

7. Constructing a new drop ceiling.

8. Abating limited ACM and LBP in other areas of the building as needed.

9. Disposing of waste at an appropriately licensed landfill under applicable waste manifests at a facility that can receive for ACWMs, LBP and mold-impacted building materials.

4.3 Cleanup Alternative Evaluation
To satisfy EPA requirements, three characteristics of each alternative -- effectiveness, implementability, and cost -- must be considered prior to selecting a recommended cleanup alternative. These characteristics are considered for each alternative in the following sections.

4.3.1 EFFECTIVENESS
Effectiveness has both short-term and long-term components. The short-term effectiveness of a remedial alternative is evaluated relative to its effect on human health and the environment during the implementation of the remedial action. Potential risks to the community, potential impacts on workers, the effectiveness and reliability of protective measures, potential environmental impact of the remedial action and the effectiveness/reliability of the mitigation measures during implementation, etc. are some of the factors that are typically considered. Long-term effectiveness and permanence of a remedial alternative are evaluated with respect to the following factors: magnitude of residual risk to human health and environment from the untreated or residual waste at the completion of remedial activities; an assessment of type, degree, and adequacy of long- term management (engineering controls, monitoring, maintenance, etc.) required for untreated or residual waste; an assessment of the long-term reliability of long-term management practices to provide continued protection from the untreated/residual waste; and the potential need for replacement of the remedy and continuing need for repairs to maintain the performance of the remedy.

4.3.1.1 Alternative 1 (No Action)
The No Abatement Alternative would use engineering and institutional controls (e.g., locked doors, signage) to manage identified ACMs and other hazardous materials in- place within the Subject Property building.

Project Number: 203724380 9

Analysis of Brownfield Cleanup Alternatives
4 EVALUATION OF CLEANUP ALTERNATIVES
December 5, 2025
Various engineering and institutional controls, if properly implemented, would be effective in mitigating the risk associated with ACM and LBP presence by minimizing or eliminating human exposure to these materials. However, maintaining the existing building roof would create an increased risk of exposure and building envelope/roof failure with time. The effectiveness of this alternative requires initial measures to isolate hazards, and continued management to maintain hazard isolation and maintain fair condition of the roof. The overall effectiveness of Alternative 1 is considered poor as the long- term reliability of on- going management is considered challenging and roofing will eventually need to be removed and replaced. In addition, Alternative 1 would not allow the Subject Property to be redeveloped.

4.3.1.2 Alternative 2 (Encasement/Enclosure)
Encasement/enclosure is considered to be an effective method in addressing ACMs within the ceiling.

However, encasement/enclosure is considered to be less effective in addressing mold. Full removal of the ceiling and other interior finishings (drywall, carpeting, wall panels, insulation, non -structural walls and partitions, etc.) i s recommended by abatement contractor s in order to e ffectively access and treat mold - impacted areas of the building that may also have been subject to water damage. This alternative does not propose access to all areas of the building that may have mold (i.e. above the ceiling). The long- term effectiveness of this alternative could be compromised by ongoing leaks in the r oof that could develop in the future as this alternative does not include a full roof replacement and only limited roof repairs. Given the state of disrepair to the roof, with some areas of failure, the effectiveness of limited repairs (i.e., patching of holes in the roof) is likely to be short -term solution, at best, that may result in a reoccurrence of mold.

Another consideration for this alternative is that the facility would need to “maintain” asbestos in the ceiling in perpetuity and would need to develop and implement a site -specific asbestos operations and maintenance (O&M) plan. Maintenance of the ACMs behind encapsulation would require an AHERA - certified professional to make repairs to the building which may also require annual inspection and maintenance. There would also be the on-going need to provide annual notifications to employees and occupants. The overall effectiveness of Alternative 2 is considered poor due to the roof’s state of disrepair, likely reoccurrence of mold, cost and long-term O&M requirements associated with encapsulation.

4.3.1.3 Alternative 3 (Removal)
The Complete Abatement of ACM Alternative would use abatement to remove all identified ACM, LBP and mold within the interior of the building. This alternative would also replace the building ceilings and roof.

With all ACMs and hazardous materials abated from the building and the roof replaced, the risk to human health associated with exposure would be eliminated. There would be no need for ongoing engineering and institutional controls. The overall effectiveness of Alternative 3 is considered good.

4.3.2 ABILITY TO IMPLEMENT
An assessment of implementability is intended to evaluate whether, or with how much difficulty, the cleanup alternative can be implemented and whether the alternative’s continued effectiveness can be assessed and verified.

Project Number: 203724380 10

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4.3.2.1 Alternative 1 (No Action)
Alternative 1 has generally already been implemented by the Subject Property owner . Stantec recommends, if this alternative is anticipated to continue to be implemented for multiple years, that additional measures be taken to ensure the isolation of ACM in poor condition from the Subject Property owner and authorized personnel that may enter the building. Furthermore, the effectiveness of Alternative 1 may be verifiable depending on the condition of the building through the collection and analysis of air samples for ACM fibers. Alternative 1 is considered good to moderately easy to implement as it will require monitoring of institutional and engineering controls to mitigate exposure to and further release of ACM.

However, Alternative 1 would not allow for the Subject Property to be redeveloped.

4.3.2.2 Alternative 2 (Encasement/Enclosure)
Encasement/enclosure is also considered relatively implementable. Both the ACMs and mold abatement would have similar requirements in terms of establishing appropriate containment, barrier, and air-filtration systems – assuming that a single remedial contractor can be used to perform both types of abatement.

However, leaving the existing ceiling and roof structure in place would likely complicate efforts to inspect, repair, or treat the roof and areas above the ceiling. Furthermore, working to preserve the ceiling and encapsulate ACMs in portions of the building will require close oversight and coordination with the abatement contractor. These activities will require close monitoring and documentation to be able to manage the building in the future. This alternative comes with significant risk of recontamination of mold after encasement/encapsulation is complete as there is a high likelihood that some mold spores would remain in structural materials (particularly in the roofing structure) and the roof is not considered to be competent to preserve the building envelope post remediation. In addition, this alternative would result in on-going future maintenance, monitoring, and/or notification requirements for ACM in building materials.

4.3.2.3 Alternative 3 (Removal)
Removal is considered relatively easy to implement and would provide advantages (over Alternative 2) as a result of the area above the ceiling up to the roof becoming fully visible and accessible. Some additional construction work would be needed for the roof replacement, but this work could likely be performed after ACM, LBP, and mold have been abated and thereby not require specialized safety equipment to protect the workers.

4.3.3 COSTS
Estimated costs were prepared for each of the three alternatives as presented in Appendix D. These costs are considered to be rough order of magnitude (ROM) cost estimates based on subcontractor bids from three regional qualified asbestos abatement contractors, professional judgement and experience, and in consideration of several key assumptions as described in the subsections above. These costs should be refined once an alternative is selected.

Project Number: 203724380 11

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December 5, 2025

4.3.3.1 Alternative 1 (No Action)
The ROM cost associated with Alternative 1 is approximately $0. There are likely costs associated with 1) added isolation measures for ACMs in poor condition; 2) continued monitoring to evaluate whether materials that are presently intact deteriorate over time; and 3) maintaining the building envelope; 4) inevitable demolition of the building if it is not maintained. These broad considerations have not been incorporated into the ROM cost estimate as there are many other building management and maintenance considerations if the No Action Alternative is implemented. This also does not account for the considerable lost opportunity cost of leaving the Subject Property unfit for community use.

4.3.3.2 Alternative 2 (Encapsulation/Enclosure)
The ROM cost estimate for this alternative is $675,400. This estimate includes cleanup of limited ACMs listed in Table 2.1 and encapsulation of remaining ACMS with limited roof repairs, which is assumed to contain ACM. This alternative would not result in unrestricted use of the Subject Property as long-term O&M would be required to maintain encapsulated areas. The ROM cost estimate for Alternative 2 includes an O&M budget of $1,500 annually for a 30-year period to allow for regular maintenance and notifications, as well as the cost of a roofing overlay to encapsulate ACM roofing materials and ongoing engineering and institutional controls to protect the safety of Subject Property workers. These O&M cost estimates are likely to increase substantially when future building alteration would affect these encapsulated areas. This estimate includes third party oversight during abatement activities for a period of 3 weeks and also includes closeout reporting to be submitted to various regulatory agencies once the project is complete.

4.3.3.3 Alternative 3 (Removal)
The ROM cost estimate for this alternative is $1,194, 000. This includes the removal of all identified ACM and LBP in the building and the removal of all interior finishes to remove and clean mold. This alternative also includes a roof replacement which is necessary to restore the building envelope properly once the ceiling is exposed. This estimate includes oversight during abatement activities for a period of 6 weeks and closeout reporting to be submitted to various regulatory agencies once the project is complete.

4.3.4 GREEN REMEDIATION CONSIDERATIONS
The carbon footprint associated with asbestos and other hazardous abatement is relatively small. ACM waste requires disposal in an appropriately -licensed landfill. The American Avenue Landfill is located 25 miles from the Subject Property so the carbon footprint associated with non -friable ACM transport for disposal will be relatively small. Finally, reuse of the Subject Property building would have a much smaller carbon footprint than demolition of the building and construction of a new building of similar function and size. So overall adaptive reuse of existing brownfield structures is considered a form of green remediation.

Project Number: 203724380 12

Analysis of Brownfield Cleanup Alternatives
4 EVALUATION OF CLEANUP ALTERNATIVES
December 5, 2025

4.4 Recommended Cleanup Alternative
To quantitatively evaluate the three cleanup alternatives, the following point system is utilized:
• Good – 5 points
• Good-Moderate – 4 points
• Moderate – 3 points
• Moderate-Poor – 2 points
• Poor – 1 point
• Not Applicable (N/A) – 0 points
Alternative Effectiveness Implementability Cost Score
Alternative 1 Poor: 1 N/A: 0 Good: 5 6
Alternative 2 Moderate: 3 Moderate: 3 Moderate: 3 9
Alternative 3 Good: 5 Good: 5 Moderate: 3 13
Based upon this quantitative scoring system for the Subject Property, Alternative 3: Complete Abatement Of ACM, LBP, and mold with Roof Replacement is recommended. The incremental cost savings to encapsulate the roof versus replacing the roof is fairly negligible considering how ineffective Alternative 2 is in both short-term and long-term contexts. Implementation of Alternative 3 also frees the Subject Property owner from ongoing long-term implementation and management of engineering and institutional controls to control RBM hazards identified throughout the building.

Project Number: 203724380 13

5 Analysis of Brownfield Cleanup Alternatives
References
Krazan and Associates, Inc. (Krazan). 2024. Asbestos Survey, Commercial Property, 887 Fulton Street, Fresno, California 93721. October 29.

Krazan. 2025. Lead-Based Paint Survey, Commercial Property, 887 Fulton Street, Fresno, California.

July 22.

Krazan. 2024. "Phase I Environmental Site Assessment, Commercial Property, 887 Fulton Street, APN 468-282-21T, Fresno, California 93721." July 11.

U.S. Environmental Protection Agency (USEPA). 1987. 40 Code of Federal Regulations (CFR) Part 763; Asbestos-Containing Materials in Schools; Final Rule. October.

U.S. Department of Housing and Urban Development. 1997. Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing. Chapter 7: Lead-Based Paint Inspection.

Project Number: 203724380 A-1

FIGURES
Los Angeles
San Francisco
Fresno
Disclaimer: This document has been prepared based on information provided by others as cited in the Notes section. Stantec has not verified the accuracy and/or completeness of this information and shall not be responsible for any errors or omissions which may be incorporated herein as a result. Stan tec assumes no responsibility for data supplied in electronic format, and the recipient accepts full responsibility for verifying the accuracy and completeness of the data.

Subject Property Boundary
Notes

1. Coordinate System: NAD 1983 UTM Zone 10N
2 . Background: USGS The National Map: National Boundaries Dataset, 3DEP Elevation Program, Geographic Names Information System, National Hydrography Dataset, National Land Cover Database, National Structures Dataset, and National Transportation Dataset; USGS Global Ecosystems; U.S. Census Bureau TIGER/Line data; USFS Road data; Natural Earth Data; U.S.

Department of State HIU; NOAA National Centers for Environmental Information. Data refreshed July, 2025., Sources: Esri, TomTom, Garmin, FAO, NOAA, USGS, © OpenStreetMap contributors, and the GIS User Community
(At original document size of 8.5x11)
1:10,000
0 500 1,000
Feet Client/Project
Figure No.

Project Location
T
itle
Parcel Number: 468-282-21T (0.24 Acres)
887 Fulton Street
Fresno, California 93721
203724380
City of Fresno
EPA Revolving Loan Fund Grant

Analysis of Brownfield Cleanup
Alternatives Report
Subject Property Location Map
1 Vacant
Commercial
Building
Social Security
Building
Vacant
Commercial
Building
Vacant
Commercial Retail
Building
Chuckchansi
Park

FULTON MALL

KERN ST
Disclaimer: This document has been prepared based on information provided by others as cited in the Notes section. Stantec has not verified the accuracy and/or completeness of this information and shall not be responsible for any errors or omissions which may be incorporated herein as a result. Stantec assumes no responsibility for data supplied in electronic f ormat, and the recipient accepts full responsibility for verifying the accuracy and completeness of the data.

C:\working\203724380_fresno\gis\pro\887_fulton_ph1esa_20250731.aprx Revised: 2025-07-31 By: awisher Subject Property Boundary
Notes

1. Coordinate System: NAD 1983 UTM Zone 10N

2. Background: © OpenStreetMap (and) contributors, CC-
BY-SA
(At original document size of 8.5x11)
1:800
0 50 100
Feet
Client/Project
Figure No.

Project Location
Title
203724380
Subject Property Project Area
Map
2 Parcel Number: 468-282-21T (0.24 Acres)
887 Fulton Street
Fresno, California 93721
City of Fresno
EPA Revolving Loan Fund Grant
Analysis of Brownfield Cleanup
Alternatives Report

APPENDIX A - Proposed
Building Renovation Plans

RETAIL/COMMERCIAL
SPACE #1
930 SF

RETAIL/COMMERCIAL
SPACE #2
840 SF

RETAIL/COMMERCIAL
SPACE #4
1000 SF

RETAIL/COMMERCIAL
SPACE #3
650 SF

RETAIL/COMMERCIAL
SPACE #5

RETAIL/COMMERCIAL
SPACE #6

RETAIL/COMMERCIAL
SPACE #7
Chukchansi Park-Home to the Washington Nationals AAA baseball team, The Fresno Grizzlies, Fresno City Hall, Fresno City College in the Guarantee Building on Fulton Street, City and County Government Administrative Offices, Tioga Sequoia Brewery, Community Regional Medical Center, Amtrak and other intermodal stations, Future home to Fresno's High Speed Rail Station

APPENDIX B - Property
Floor Plans

APPENDIX C - Regulated
Building Materials Survey
Reports

ASBESTOS SURVEY

COMMERCIAL PROPERTY
887 FULTON STREET

FRESNO, CALIFORNIA
Project No. 014-24091
October 29, 2024
Prepared for:

Dora Westerlund
Fresno Area Hispanic Foundation
c/o The Taylor Group Architects
410 Park Creek Drive
Clovis, California 93721
(559) 708-4046
Prepared by:

Krazan & Associates, Inc.
215 West Dakota Avenue
Clovis, California 93612
(559) 348-2200

TABLE OF CONTENTS
Project No. 014-24091
Page

1.0 INTRODUCTION.............................................................................................................. ............... 1

2.0 PURPOSE AND SCOPE OF WORK................................................................................................. 1

3.0 BUILDING DESCRIPTION....................................................................................................... ....... 1

4.0 INVESTIGATIVE METHODS ..................................................................................................... .... 2

4.1 Sampling Protocols ........................................................................................................ ................ 2

4.2 Laboratory Analytical Methods ............................................................................................. ......... 2

5.0 RESULTS OF INVESTIGATION.................................................................................................. ... 2

6.0 CONCLUSIONS............................................................................................................... ................ 3

7.0 LIMITATIONS ............................................................................................................... .................. 4 Figures
Asbestos Survey Results....................................................................................................... following text Floor Plan..................................................................................................................... .. following Results Appendices
Analytical Results and Chain-of-Custody Record ................................................................................ ... A DOSH Certifications ........................................................................................................... ................... B

& A S S O C I A T E S , I N C .

GEOTECHNICAL ENGINEERING x ENVIRONMENTAL ENGINEERING

CONSTRUCTION TESTING & INSPECTION
October 29, 2024 Project No. 014-24091

ASBESTOS SURVEY

COMMERCIAL PROPERTY
887 FULTON STREET

FRESNO, CALIFORNIA

1.0 INTRODUCTION
This report presents the results of our asbestos survey for the structure located at 887 Fulton St. in Fresno, California. The asbestos survey was conducted under the conditions of Krazan & Associates, Inc.’s (Krazan’s) Proposal No. P24-274, dated September 17, 2024. Dora Westerlund gave written authorization on September 25, 2024, for Krazan to proceed with the asbestos survey.

2.0 PURPOSE AND SCOPE OF WORK
The purpose of the asbestos survey was to identify and quantify the presence of potential asbestos- containing materials (ACMs) at the on-site structure. The scope of work for the asbestos survey included conducting a visual survey of the structure and conducting bulk sampling and analysis of materials suspected to contain asbestos. This survey was performed in accordance with applicable local, state, and federal regulations.

3.0 BUILDING DESCRIPTION
The structure was a two-story structure with basement, stucco, brick, and ceramic tiled exterior walls, with mineral surface rolled roofing. Interior construction included gypsum board, acoustic ceiling tiles, plaster, and suspended ceilings with two-foot by four-foot ceiling panels; gypsum board, plaster, wood, brick, concrete block, open-framed, and ceramic tiled walls; and concrete floors overlain (in areas) by wall-to-wall carpeting, floor tiles, ceramic tiles, and terrazzo. 215 West Dakota Avenue • Clovis, California 93612 • (559) 348-2200 • FAX (559) 348-2190 With Offices Serving the Western United States
1424091 Asbestos

Project No. 014-24091
Page No. 2

4.0 INVESTIGATIVE METHODS

4.1 Sampling Protocols
Sixty-two (62) samples of suspected ACMs were collected from throughout the on-site structure. Sample locations for this survey were chosen in a semi-random fashion with emphasis placed on minimizing damage to the sampled materials. The samples were collected by carefully removing a small amount of the suspect material in a non-abrasive manner. If possible, samples were collected from existing damaged areas or loose pieces of materials. Each sample was placed in a separate sealed plastic bag, and labeled with the project number and sample number. Refer to the Floor Plan following the text for the bulk sample locations.

4.2 Laboratory Analytical Methods
The bulk samples collected were analyzed by E.H.S. Laboratories of Richmond, Virginia, to detect the presence, type, and percentage of asbestos by polarized light microscopy/dispersion staining, following the procedure described in 40 CFR 763, Subpart E, Appendix A (AHERA). Copies of the Analytical Results and Chain-of-Custody Record are included in Appendix A.

5.0 RESULTS OF INVESTIGATION
As stated previously, 62 samples of suspected ACMs were collected from throughout the structure.

Analytical laboratory results and field observations of the materials sampled have been summarized on Table I, following the text of this report. Information presented within the table includes the sample number, the sample description, the location where the sample was obtained, the asbestos content, the volume of ACMs identified (typically expressed in square feet), the condition of the material sampled, and a listing of locations where similar (homogenous) ACMs were also noted (although not necessarily sampled in these areas). In addition, footnotes have been provided to convey pertinent information regarding the specific sample or homogenous material.

The following materials were identified as containing at least one percent asbestos:

Texture associated with drywall – throughout structure (Sample Nos. 14, 15, 16, 17, 18, and19). This material would be considered a friable ACM under the NESHAP Regulations. 9-in by 9-in Floor tile and associated mastic – throughout structure (Sample Nos.33, 34, 35, 36, 37, 39, 40, and 62). This material would be considered a Category I non-friable ACM under the NESHAP Regulations.

KRAZAN & ASSOCIATES, INC.

With Offices Serving the Western United States
1424091 Asbestos

Project No. 014-24091
Page No. 3
The following materials were identified as containing at least one percent asbestos: (continued) Pipe elbow insulation – basement mechanical room (Sample No. 49). This material would be considered a friable ACM under the NESHAP Regulations.

Roof core – roof (Sample No. 55). This material would be considered a Category I non-friable ACM under the NESHAP Regulations.

Roof mastic – on metal wall cap on roof (Sample No. 60). This material would be considered a Category I non-friable ACM under the NESHAP Regulations.

Vent pipe – on steam generator in basement (Assumed asbestos). This material would be considered a Category II non-friable ACM under the NESHAP Regulations.

The following materials were identified as containing trace asbestos, NESHAPs composite results.

Gypsum board and taping material – throughout structure (Sample Nos. 8, 9, 10, 11, 12, and 13).

6.0 CONCLUSIONS
The National Emissions Standards for Hazardous Air Pollutants (NESHAP) defines regulated asbestos- containing materials (RACM) as the following: friable materials containing more than one percent asbestos as determined by polarized light microscopy; Category I non-friable materials (i.e., floor tiles, asphalt roofing products) containing more than one percent asbestos that have become friable, have been subjected to or will be subjected to sanding, grinding, cutting, or abrading; and Category II non-friable materials (i.e., non-friable asbestos-containing materials that are not Category I materials) containing more than one percent asbestos that have a high probability of becoming or have already been reduced to a friable condition by demolition or renovation activities. The above-noted samples that contain greater than one percent asbestos and friable meet the definition of a RACM under the NESHAP. Depending on the abatement method employed the above noted samples that contain greater than one percent asbestos and considered non-friable may also become RACM. In addition, the California Division of Occupational Safety and Health (Cal-OSHA) defines asbestos-containing construction material (ACCM) as greater than 0.1 percent asbestos. The above-noted samples that contain greater than 0.1 percent asbestos would meet the definition of an ACCM.

If these asbestos-containing materials are left in place, the occupants of the structure should avoid buffing, sanding, grinding, or abrading these materials in any way. These activities could potentially release asbestos fibers. An Operations and Maintenance Program (O&M Program) could be developed for the management of asbestos-containing materials if left in place. The development and KRAZAN & ASSOCIATES, INC.

With Offices Serving the Western United States
1424091 Asbestos

Project No. 014-24091
Page No. 4
implementation of such a program would require the designation and training of an asbestos program manager. The asbestos program manager would be responsible for conducting periodic inspections of the asbestos-containing materials, record keeping requirements, and providing awareness training necessary for any maintenance or custodial personnel required to clean or repair these materials. Furthermore, it is recommended that the asbestos program manager notify all potentially affected individuals.

When building maintenance, repair, renovation, or other activities disturb or damage ACMs, asbestos fibers may be released creating a potential hazard. Therefore, removal of friable and non-friable ACMs that have the potential to become friable during demolition and/or renovation is federally regulated under the NESHAP. The San Joaquin Valley Air Pollution Control District (APCD) is the responsible agency on the local level to enforce the NESHAP. The APCD Regional Office requires that asbestos-containing materials (ACM) be removed prior to renovation or demolition activities. Additionally, the APCD must be notified prior to any demolition and/or renovation activities.

7.0 LIMITATIONS
This survey and review of the subject property has been limited in scope. This investigation is undertaken with the risk that visual observations and random sampling alone would not reveal the presence, full nature, and extent of asbestos-containing materials. Krazan makes no representation as to the asbestos content of materials not sampled or that were inaccessible to our inspector (i.e., between walls, beneath floors, in pipe chases, etc.). The asbestos sample locations and building dimensions were measured/located in the field by tape measurement from existing features. Therefore, the sample locations, building dimensions, and approximate square footage of asbestos-containing materials should be considered accurate only to the degree implied by the methods used.

The findings presented in this report were based on field observations, random sampling and analysis, review of available data, and discussions with local regulatory and advisory agencies. Therefore, the data obtained are clear and accurate only to the degree implied by the sources and methods used. The information presented herewith was based on professional interpretation using presently accepted methods with a degree of conservatism deemed proper as of the report date. We do not warrant that future technical developments cannot supersede such data.

KRAZAN & ASSOCIATES, INC.

With Offices Serving the Western United States
1424091 Asbestos

Project No. 014-24091
Page No. 5
This asbestos survey is not intended to be the sole basis for asbestos removal bids. Confirmation of the condition and volume of the ACMs should be conducted by prospective removal contractors prior to accepting removal bids. This report is provided for the exclusive use of the client noted on the cover page and is subject to the terms and conditions in the applicable contract between the Client and Krazan. The client is the only party to whom Krazan has explained the risks involved and has been involved in the shaping of the scope of services needed to satisfactorily manage those risks, if any, from the client’s point of view. Any third party use of this report, including use by the Client’s lender, prospective purchaser, or lessee will be subject to the terms and conditions governing the contractual work between the Client and Krazan. The unauthorized use of, reliance on, or release of the information contained in this report, without the expressed written consent of Krazan, is strictly prohibited and will be without risk or liability to Krazan.

Asbestos analysis was conducted by a laboratory accredited under the National Voluntary Laboratory Accreditation Program (NVLAP) administered by the National Institute of Standards and Technology (NIST). The results of the asbestos analyses are accurate only to the degree and care of ensuring the testing accuracy and the representative nature of the samples obtained.

If you have any questions or if we may be of further assistance, please do not hesitate to contact our office at (559) 348-2200.

Respectfully submitted,
KRAZAN & ASSOCIATES, INC.

Jeffrey R. Noël
DOSH Certified Asbestos Consultant
No. 00-2828
JRN/mlt
KRAZAN & ASSOCIATES, INC.

With Offices Serving the Western United States
1424091 Asbestos

TABLE I

ASBESTOS ANALYSIS RESULTS
Commercial Property
887 Fulton Street
Fresno, California
October 14, 2024 Sampling
Asbestos Approx. Condition / Notes/
Sample No. Sample Description Sample Location Content Sq. Ft. Friability Additional locations 1 Plaster 2nd floor ND NC NA homogenous throughout
2 Plaster 1st floor ND NC NA homogenous throughout
3 Plaster basement ND NC NA homogenous throughout
4 Skim coat 2nd floor ND NC NA homogenous throughout
5 Skim coat 1st floor ND NC NA homogenous throughout
6 Skim coat basement ND NC NA homogenous throughout
7 Gypsum board 2nd floor ND NC NA plaster backer board, homogenous throughout 8 Gypsum board / taping material 2nd floor Trace see # 14 NA homogenous throughout 9 Gypsum board / taping material 2nd floor Trace see # 14 NA homogenous throughout 10 Gypsum board / taping material 1st floor Trace see # 14 NA homogenous throughout 11 Gypsum board / taping material 1st floor Trace see # 14 NA homogenous throughout 12 Gypsum board / taping material basement Trace see # 14 NA homogenous throughout 13 Gypsum board / taping material basement Trace see # 14 NA homogenous throughout 14 Texture 2nd floor 4% 60,000 G/FR homogenous throughout 15 Texture 2nd floor 4% see # 14 G/FR homogenous throughout 16 Texture 1st floor 4% see # 14 G/FR homogenous throughout 17 Texture 1st floor 4% see # 14 G/FR homogenous throughout 18 Texture basement 4% see # 14 G/FR homogenous throughout 19 Texture basement 4% see # 14 G/FR homogenous throughout 20 Wallpaper 2nd floor ND NC NA
21 Wallpaper 2nd floor ND NC NA
22 Wallpaper 2nd floor ND NC NA
23 Wallpaper 2nd floor ND NC NA
24 Wallpaper 2nd floor ND NC NA
25 Wallpaper 1st floor ND NC NA
26 Wallpaper 1st floor ND NC NA
27 Wallpaper basement ND NC NA
28 12-in by 12-in Ceiling tile basement ND NC NA main
29 12-in by 12-in Ceiling tile basement ND NC NA patch
30 12-in by 12-in Ceiling tile basement ND NC NA patch
31 2-ft by 4-ft Ceiling panel 1st floor ND NC NA vinyl wrapped gypsum board NA = Not applicable F = Fair condition
NC = Not calculated G = Good condition
ND = None detected NF = Non-friable
Trace = Less than one percent (<1%) chrysotile asbestos FR = Friable KRAZAN & ASSOCIATES, INC.

Serving the Western United States 1424091 Asbestos
TABLE I (Continued)

ASBESTOS ANALYSIS RESULTS
Commercial Property
887 Fulton Street
Fresno, California
October 14, 2024 Sampling
Asbestos Approx. Condition / Notes/
Sample No. Sample Description Sample Location Content Sq. Ft. Friability Additional locations 32 2-ft by 4-ft Ceiling panel 1st floor ND NC NA vinyl wrapped gypsum board 33 9-in by 9-in Floor tile / mastic 2nd floor 4% / 4% 600 G/NF brown streaked 34 9-in by 9-in Floor tile / mastic 2nd floor 5% / 4% 450 G/NF gray streaked 35 9-in by 9-in Floor tile 2nd floor 6% 700 G/NF tan
36 9-in by 9-in Floor tile / mastic 2nd floor 5% / 4% 75 G/NF tan 37 9-in by 9-in Floor tile / mastic 1st floor 4% / 4% 600 G/NF brown streaked 38 9-in by 9-in Floor tile / mastic 1st floor ND NC NA yellow 39 9-in by 9-in Floor tile / mastic basement 4% / 4% 800 G/NF tan 40 9-in by 9-in Floor tile / mastic basement 4% / 5% 300 G/NF green streaked 41 Stair tread basement ND NC NA
42 Ceiling tile mastic basement ND NC NA
43 Base cove mastic basement ND NC NA
44 Base cove mastic 1st floor ND NC NA
45 Base cove mastic 2nd floor ND NC NA
46 Paneling mastic 1st floor ND NC NA
47 Ducting tape basement ND NC NA on metal ducting seams 48 Ducting tape basement ND NC NA on metal ducting seams 49 Pipe elbow basement 8% <50 G/FR
50 Pipe insulation wrap basement ND NC NA over fiberglass insulation 51 Pipe insulation wrap basement ND NC NA over fiberglass insulation 52 Stucco exterior ND NC NA homogenous throughout
53 Stucco exterior ND NC NA homogenous throughout
54 Stucco exterior ND NC NA homogenous throughout
55 Roof core roof 15% 11,000 G/NF full depth core
56 Roof tar roof ND NC NA between roofing layers and s eams 57 Roof mastic roof ND NC NA roof penetrations
58 Roof mastic roof ND NC NA roof patch
59 Roof mastic roof ND NC NA roof patch
60 Roof mastic roof 8% <100 G/NF on metal wall cap
61 Terrazzo flooring 1st floor ND NC NA at front and side entry 62 9-in by 9-in Floor tile / mastic 2nd floor 4% / 4% 200 G/NF brown streaked --- Vent pipe basement Assumed 75 G/NF
NA = Not applicable F = Fair condition
NC = Not calculated G = Good condition
ND = None detected NF = Non-friable
Trace = Less than one percent (<1%) chrysotile asbestos FR = Friable KRAZAN & ASSOCIATES, INC.

Serving the Western United States 1424091 Asbestos
1,4,7 34
59 23
35 15
55,56
36 58
57 629 60
52 61 53
32 31
46 44
26 25
38 172,5
11 40 12 27
3,6
30 39
28 13
29 43
41 49,50
48 42 19
47 EXPLANATION

BUILDING MATERIAL SAMPLE LOCATION
24 14
18 22
20 8
45 33
21 10
16 37
Second
Floor
54 First
Floor
Basement
Level

FLOOR PLAN WITH BUILDING MATERIAL

SAMPLE LOCATIONS

COMMERCIAL PROPERTY
887 FULTON STREET

FRESNO, CALIFORNIA
Scale:

NOT TO SCALE
Date:
10 / 24
Drawn by:

J. R. N.

Approved by:

J.R.N
Project No.
014-24091
Figure No.
1 Appendix A
Asbestos Bulk
Analysis Report
7469 Whitepine Rd
North Chesterfield, VA 23237
Telephone: 800.347.4010 Report Number: 24-10-02952
Client: Krazan & Associates Inc. Received Date: 10/15/2024 215 West Dakota Ave Analyzed Date: 10/18/2024, 10/19/2024 Clovis, CA 93612 Reported Date: 10/22/2024
Project/Test Address: 014-24091; Commercial Property; 887 Fulton Street Fax Number: Client Number:
559-348-220105-5650 Laboratory Results
Lab Sample Client Sample
Number Number
24-10-02952-001 1
Layer Type Lab Gross Description
Pale Beige-Gray
Cementitious;
Homogeneous
Asbestos
NAD
Other
Materials
100% Non-Fibrous
24-10-02952-002 2 Off-White Cementitious;
White Brittle;
Inhomogeneous
NAD 1% Cellulose
99% Non-Fibrous
24-10-02952-003 3 Off-White Cementitious;
Homogeneous
NAD 100% Non-Fibrous
24-10-02952-004 4 Light Beige-Gray
Cementitious;
Homogeneous
NAD 1% Cellulose
99% Non-Fibrous
24-10-02952-005 5 Off-White Cementitious;
Homogeneous
NAD 100% Non-Fibrous

Page 1 ends

Environmental Hazards Services, L.L.C
Client Number: 05-5650 Report Number: 24-10-02952
Project/Test Address: 014-24091; Commercial Property; 887 Fulton Street
Lab Sample Client Sample Layer Type Lab Gross Description Asbestos Other Number Number Materials
24-10-02952-006 6 Off-White Cementitious; NAD 100% Non-Fibrous Homogeneous
24-10-02952-007 7 Off-White Brittle; Tan NAD 10% Cellulose Fibrous; Inhomogeneous 7% Fibrous Glass
83% Non-Fibrous
24-10-02952-008 8 Off-White/Light Beige- Trace <1% Chrysotile 12% Cellulose Gray Brittle; Tan Fibrous: 5% Fibrous Glass
83% Non-Fibrous
Light Beige Pliable to
Brittle; Inhomogeneous
Total Asbestos: Trace <1%
Chrysotile present in light beige-gray brittle joint compound-type layer; this material alone contains 4% chrysotile. 24-10-02952-009 9 Off-White/Light Beige-
Trace <1% Chrysotile 10% Cellulose
Gray Brittle; Tan Fibrous: 7% Fibrous Glass
83% Non-FibrousLight Beige Pliable to
Brittle; Inhomogeneous
Total Asbestos: Trace <1%
Chrysotile present in light beige-gray brittle joint compound-type layer; this material alone contains 4% chrysotile. 24-10-02952-010 10 Off-White/Light Beige-
Trace <1% Chrysotile 10% Cellulose
Gray Brittle; Tan Fibrous: 8% Fibrous Glass
82% Non-FibrousLight Beige Pliable to
Brittle; Inhomogeneous
Total Asbestos: Trace <1%
Chrysotile present in light beige-gray brittle joint compound-type layer; this material alone contains 4% chrysotile. 24-10-02952-011 11 Off-White/Light Beige-
Trace <1% Chrysotile 12% Cellulose
Gray Brittle; Tan Fibrous: 5% Fibrous Glass
83% Non-FibrousLight Beige Pliable to
Brittle; Inhomogeneous
Total Asbestos: Trace <1%
Chrysotile present in light beige-gray brittle joint compound-type layer; this material alone contains 4% chrysotile.

Page 2 ends

Environmental Hazards Services, L.L.C
Client Number: 05-5650 Report Number: 24-10-02952
Project/Test Address: 014-24091; Commercial Property; 887 Fulton Street
Lab Sample Client Sample Layer Type Lab Gross Description Asbestos Other Number Number Materials
24-10-02952-012 12 Off-White/Light Beige- Trace <1% Chrysotile 12% Cellulose Gray Brittle; Tan Fibrous: 5% Fibrous Glass
83% Non-Fibrous
Light Beige Pliable to
Brittle; Inhomogeneous
Total Asbestos: Trace <1%
Chrysotile present in light beige-gray brittle joint compound-type layer; this material alone contains 4% chrysotile. 24-10-02952-013 13 Off-White/Light Beige-
Trace <1% Chrysotile 10% Cellulose
Gray Brittle; Tan Fibrous: 7% Fibrous Glass
83% Non-FibrousLight Beige Pliable to
Brittle; Inhomogeneous
Total Asbestos: Trace <1%
Chrysotile present in light beige-gray brittle joint compound-type layer; this material alone contains 4% chrysotile. 24-10-02952-014 14 Pale Beige Brittle to
4% Chrysotile 1% Cellulose
Coarse Powder; Pale 95% Non-Fibrous
Mauve Pliable to Brittle;
Inhomogeneous
Total Asbestos: 4%
Chrysotile present in pale beige brittle to coarse powder texturing compound-type (main) layer. 24-10-02952-015 15 Pale Beige Brittle to 4% Chrysotile 2% Cellulose Coarse Powder; Pale 94% Non-Fibrous
Mauve Pliable to Brittle;
Inhomogeneous
Total Asbestos: 4%
Chrysotile present in pale beige brittle to coarse powder texturing compound-type (main) layer. 24-10-02952-016 16 Pale Beige Brittle to 4% Chrysotile 1% Cellulose Coarse Powder; White 95% Non-Fibrous
Pliable to Brittle;
Inhomogeneous
Total Asbestos: 4%
Chrysotile present in pale beige brittle to coarse powder texturing compound-type (main) layer. 24-10-02952-017 17 Pale Beige Brittle to 4% Chrysotile 2% Cellulose Coarse Powder; White 94% Non-Fibrous
Pliable to Brittle;
Inhomogeneous
Total Asbestos: 4%
Chrysotile present in pale beige brittle to coarse powder texturing compound-type (main) layer.

Page 3 ends

Environmental Hazards Services, L.L.C
Client Number: 05-5650 Report Number: 24-10-02952
Project/Test Address: 014-24091; Commercial Property; 887 Fulton Street
Lab Sample Client Sample Layer Type Lab Gross Description Asbestos Other Number Number Materials
24-10-02952-018 18 Off-White Brittle to Coarse 4% Chrysotile 1% Cellulose Powder; Beige Pliable to 95% Non-Fibrous
Brittle; Inhomogeneous
Total Asbestos: 4%
Chrysotile present in off-white brittle to coarse powder texturing compound-type (main) layer. 24-10-02952-019 19 Off-White Brittle to Coarse 4% Chrysotile 1% Cellulose Powder; Beige Pliable to 95% Non-Fibrous
Brittle; Inhomogeneous
Total Asbestos: 4%
Chrysotile present in off-white brittle to coarse powder texturing compound-type (main) layer. 24-10-02952-020 20 Beige/Tan Fibrous;
NAD 60% Cellulose
Inhomogeneous 30% Synthetic
10% Non-Fibrous
24-10-02952-021 21 Beige to Dark Gray NAD 85% Cellulose Fibrous; Homogeneous 15% Non-Fibrous
24-10-02952-022 22 Beige Fibrous; Off-White NAD 75% Cellulose Pliable; Inhomogeneous 25% Non-Fibrous
24-10-02952-023 23 Beige/Gray-Green/Off- NAD 80% Cellulose White Fibrous; 20% Non-Fibrous
Inhomogeneous
24-10-02952-024 24 Tan Fibrous; Off-White NAD 75% Cellulose Pliable; Inhomogeneous 25% Non-Fibrous

Page 4 ends

Environmental Hazards Services, L.L.C
Client Number: 05-5650 Report Number: 24-10-02952
Project/Test Address: 014-24091; Commercial Property; 887 Fulton Street
Lab Sample Client Sample Layer Type Lab Gross Description Asbestos Other Number Number Materials
24-10-02952-025 25 Beige Fibrous; Dark Pink NAD 30% Cellulose Pliable to Brittle; 40% Synthetic
30% Non-Fibrous
Inhomogeneous
24-10-02952-026 26 Beige Fibrous; Gray NAD 75% Cellulose Pliable to Brittle; 25% Non-Fibrous
Inhomogeneous
24-10-02952-027 27 Tan/Brown-Gray Fibrous; NAD 75% Cellulose White Brittle; 25% Non-Fibrous
Inhomogeneous
24-10-02952-028 28 Tan Fibrous; Off-White NAD 90% Cellulose Brittle; Inhomogeneous 10% Non-Fibrous
24-10-02952-029 29 Tan Fibrous; Off-White NAD 90% Cellulose Brittle; Inhomogeneous 10% Non-Fibrous
24-10-02952-030 30 Pale Gray Fibrous; White NAD 45% Cellulose Brittle; Inhomogeneous 30% Fibrous Glass
25% Non-Fibrous
24-10-02952-031 31 Pale Pink Brittle; Tan NAD 30% Cellulose Fibrous; White Vinyl-Like; 5% Fibrous Glass
65% Non-Fibrous
Translucent Adhesive;
Inhomogeneous

Page 5 ends

Environmental Hazards Services, L.L.C
Client Number: 05-5650 Report Number: 24-10-02952
Project/Test Address: 014-24091; Commercial Property; 887 Fulton Street
Lab Sample Client Sample Layer Type Lab Gross Description Asbestos Other Number Number Materials
24-10-02952-032 32 Pale Pink Brittle; Tan NAD 40% Cellulose Fibrous; White Vinyl-Like; 3% Fibrous Glass
57% Non-Fibrous
Translucent Adhesive;
Inhomogeneous
24-10-02952-033A 33 Flooring Dark Brown Granular;
4% Chrysotile 96% Non-Fibrous
Homogeneous
Total Asbestos: 4%
24-10-02952-033B 33 Mastic Black Adhesive; 4% Chrysotile 3% Cellulose Homogeneous 93% Non-Fibrous
Total Asbestos: 4%
24-10-02952-034A 34 Flooring Gray/Beige Granular; 5% Chrysotile 95% Non-Fibrous Homogeneous
Total Asbestos: 5%
24-10-02952-034B 34 Mastic Black Adhesive; 4% Chrysotile 2% Cellulose Homogeneous 94% Non-Fibrous
Total Asbestos: 4%
24-10-02952-035 35 Pale Beige-Gray Vinyl- 6% Chrysotile 94% Non-Fibrous Like; Homogeneous
Total Asbestos: 6%
Insufficient quantity of mastic on flooring sample for analysis of mastic. 24-10-02952-036A 36 Flooring Pale Beige Vinyl-Like; 5% Chrysotile 95% Non-Fibrous Homogeneous
Total Asbestos: 5%
24-10-02952-036B 36 Mastic Pale Beige Adhesive; 4% Chrysotile 2% Cellulose Homogeneous 94% Non-Fibrous
Total Asbestos: 4%

Page 6 ends

Environmental Hazards Services, L.L.C
Client Number: 05-5650 Report Number: 24-10-02952
Project/Test Address: 014-24091; Commercial Property; 887 Fulton Street
Lab Sample Client Sample Layer Type Lab Gross Description Asbestos Other Number Number Materials
24-10-02952-037A 37 Flooring Dark Brown Granular; 4% Chrysotile 96% Non-Fibrous Homogeneous
Total Asbestos: 4%
24-10-02952-037B 37 Mastic Black Adhesive; 4% Chrysotile 2% Cellulose Homogeneous 94% Non-Fibrous
Total Asbestos: 4%
24-10-02952-038A 38 Flooring Pale Beige Vinyl-Like; NAD 100% Non-Fibrous Homogeneous
24-10-02952-038B 38 Mastic Pale Beige Adhesive; NAD 2% Cellulose Homogeneous 98% Non-Fibrous
24-10-02952-039A 39 Flooring Beige Granular; 4% Chrysotile 96% Non-Fibrous Homogeneous
Total Asbestos: 4%
24-10-02952-039B 39 Mastic Black Adhesive; 4% Chrysotile 4% Cellulose Homogeneous 92% Non-Fibrous
Total Asbestos: 4%
24-10-02952-040A 40 Flooring Teal Granular; 4% Chrysotile 96% Non-Fibrous Homogeneous
Total Asbestos: 4%
24-10-02952-040B 40 Mastic Black Adhesive; 5% Chrysotile 2% Cellulose Homogeneous 93% Non-Fibrous
Total Asbestos: 5%

Page 7 ends

Environmental Hazards Services, L.L.C
Client Number: 05-5650 Report Number: 24-10-02952
Project/Test Address: 014-24091; Commercial Property; 887 Fulton Street
Lab Sample Client Sample Layer Type Lab Gross Description Asbestos Other Number Number Materials
24-10-02952-041A 41 Flooring Pale Gray/Off-White/Black NAD 1% Cellulose Vinyl-Like; Homogeneous 99% Non-Fibrous
24-10-02952-041B 41 Mastic Brown Adhesive; NAD 3% Cellulose Homogeneous 4% Talc
93% Non-Fibrous
24-10-02952-042 42 Brown Adhesive; NAD 2% Cellulose
Homogeneous 98% Non-Fibrous
24-10-02952-043 43 Brown Adhesive; NAD 3% Cellulose
Homogeneous 1% Fibrous Glass
1% Synthetic
2% Wollastonite
3% Talc
90% Non-Fibrous
24-10-02952-044 44 Brown/Translucent to NAD 2% Cellulose Yellow Adhesive; 1% Synthetic
1% Wollastonite
Inhomogeneous 4% Talc
92% Non-Fibrous
24-10-02952-045 45 Brown Adhesive; NAD 1% Cellulose
Homogeneous 7% Talc
92% Non-Fibrous
24-10-02952-046 46 Beige Adhesive; NAD 100% Non-Fibrous Homogeneous

Page 8 ends

Environmental Hazards Services, L.L.C
Client Number: 05-5650 Report Number: 24-10-02952
Project/Test Address: 014-24091; Commercial Property; 887 Fulton Street
Lab Sample Client Sample Layer Type Lab Gross Description Asbestos Other Number Number Materials
24-10-02952-047 47 Beige Fibrous; Pale Beige NAD 70% Cellulose Pliable to Brittle; 30% Non-Fibrous
Inhomogeneous
24-10-02952-048 48 Beige Fibrous; Pale Beige NAD 70% Cellulose Pliable to Brittle; 30% Non-Fibrous
Inhomogeneous
24-10-02952-049 49 Off-White Brittle; Beige 8% Chrysotile 20% Cellulose Fibrous; Pale Beige 40% Fibrous Glass
32% Non-Fibrous
Pliable to Brittle;
Inhomogeneous
Total Asbestos: 8%
Chrysotile present in off-white brittle mudded TSI-type (main) layer. 24-10-02952-050 50 Off-White/White Fibrous;
NAD 55% Cellulose
Pale Yellow Adhesive; 25% Fibrous Glass
20% Non-FibrousSilver Metallic;
Inhomogeneous
24-10-02952-051 51 Beige Fibrous; Pale Beige
NAD 75% Cellulose
Pliable to Brittle; 25% Non-Fibrous
Inhomogeneous
24-10-02952-052 52 Gray Cementitious; Light NAD 100% Non-Fibrous Pink Pliable to Brittle;
Inhomogeneous
24-10-02952-053 53 Gray Cementitious; Light
NAD 100% Non-Fibrous
Pink Pliable to Brittle;
Inhomogeneous

Page 9 ends

Environmental Hazards Services, L.L.C
Client Number: 05-5650 Report Number: 24-10-02952
Project/Test Address: 014-24091; Commercial Property; 887 Fulton Street
Lab Sample Client Sample Layer Type Lab Gross Description Asbestos Other Number Number Materials
24-10-02952-054 54 Gray Cementitious; Light NAD 100% Non-Fibrous Pink Pliable to Brittle;
Inhomogeneous
24-10-02952-055 55 Dark Brown/Black Fibrous;
15% Chrysotile 15% Cellulose
Black Pliable to Brittle; 5% Fibrous Glass
65% Non-Fibrous
White Pliable; Off-White
Aggregate;
Inhomogeneous
Total Asbestos: 15%
Chrysotile present in dark brown fibrous felt-type layers throughout sample. 24-10-02952-056 56 Black Brittle;
NAD 1% Cellulose
Homogeneous 99% Non-Fibrous
24-10-02952-057 57 Black/Silver Pliable to NAD 25% Cellulose Brittle; Inhomogeneous 75% Non-Fibrous
24-10-02952-058 58 Black Pliable to Brittle; NAD 30% Cellulose Homogeneous 70% Non-Fibrous
24-10-02952-059 59 Black Pliable to Brittle; NAD 15% Cellulose Homogeneous 3% Fibrous Glass
82% Non-Fibrous
24-10-02952-060 60 Black to Gray Pliable to 8% Chrysotile 2% Cellulose Brittle; Homogeneous 90% Non-Fibrous
Total Asbestos: 8%

Page 10 of 11 ends

Environmental Hazards Services, L.L.C
Client Number: 05-5650 Report Number: 24-10-02952
Project/Test Address: 014-24091; Commercial Property; 887 Fulton Street
Lab Sample Client Sample Layer Type Lab Gross Description Asbestos Other Number Number Materials
24-10-02952-061 61 Off-White/Pale Gray NAD 100% Non-Fibrous Cementitious;
Homogeneous
24-10-02952-062A 62 Flooring Dark Brown/Beige
4% Chrysotile 96% Non-Fibrous
Granular; Homogeneous
Total Asbestos: 4%
24-10-02952-062B 62 Mastic Black Adhesive; 4% Chrysotile 3% Cellulose Homogeneous 93% Non-Fibrous
Total Asbestos: 4%
QC Sample: 98-M22012-1, 99-M22012-2
QC Blank: SRM 1866 Fiberglass
Reporting Limit: 1% Asbestos
Method: EPA Method 600/R-93/116, EPA Method 600/M4-82-020 Analyst: Mark Case
Reviewed By Authorized Signatory:

Melissa Kanode
QA/QC Clerk
These results are based on a comparative visual estimate. The condition of the samples analyzed was acceptable upon receipt pe r laboratory protocol unless otherwise noted on this report. Each distinct component in an inhomogeneous sample was analyzed separately and reported as a composite.

Results represent the analysis of samples submitted by the client. Sample location, description, area, volume, etc., was provided by the client. This report cannot be used by the client to claim product endorsement by NVLAP or any agency of the U.S. Government. This report shall not be reproduced except in full, without the written consent of the Environmental Hazards Service, L.L.C. All information concerning sampling location, date, and time can be found on Chain-of-Custody. Environmental Hazards Services, L.L.C. does not perform any sample collection. . NVLAP #101882-0 VELAP 460172 Environmental Hazards Services, L.L.C. recommends reanalysis by point count (for more accurate quantification) or Transmission Electron Microscopy (TEM), (for enhanced detection capabilities) for materials regulated by EPA NESHAP (National Emission Standards for Hazardous Air Pollutants) and found to contain less than ten percent (<10%) asbestos by polarized light microscopy (PLM). Both services are available for an additional fee. 400 Point Count Analysis, where noted, performed per EPA Method 600/R-93/116 with a Reporting Limit of 0.25%.

LEGEND: NAD = no asbestos detected

Page 11 of 11 ends

Appendix B

LEAD-BASED PAINT SURVEY

COMMERCIAL PROPERTY
887 FULTON STREET

FRESNO, CALIFORNIA
Project No. 014-25015
July 22, 2025
Prepared for:

Dora Westerlund
Fresno Area Hispanic Foundation
1444 Fulton Street
Fresno, California 93721
(559) 222-8705
Prepared by:

Krazan & Associates, Inc.
215 West Dakota Avenue
Clovis, California 93612
(559) 348-2200

TABLE OF CONTENTS
Project No. 014-25015
Page

1.0 INTRODUCTION............................................................................................................................. 1

2.0 PURPOSE AND SCOPE OF WORK................................................................................................. 1

3.0 BUILDING DESCRIPTION.............................................................................................................. 1

4.0 INVESTIGATIVE METHODS ......................................................................................................... 2

4.1 Sampling Protocols ........................................................................................................................ 2

4.2 Laboratory Analytical Methods ...................................................................................................... 2

5.0 RESULTS OF INVESTIGATION..................................................................................................... 2

6.0 CONCLUSIONS............................................................................................................................... 3

7.0 LIMITATIONS ................................................................................................................................. 4 Figures
Lead-Based Paint Survey Results (Table I)...........................................................................following text Floor Plan with Sample Locations .................................................................................. following Results Appendices
Analytical Results and Chain-of-Custody Record ................................................................................... A DPH Certifications................................................................................................................................. B

& A S S O C I A T E S , I N C .

GEOTECHNICAL ENGINEERING  ENVIRONMENTAL ENGINEERING

CONSTRUCTION TESTING & INSPECTION
July 22, 2025 Project No. 014-25015

LEAD-BASED PAINT SURVEY

COMMERCIAL PROPERTY
887 FULTON STREET

FRESNO, CALIFORNIA

1.0 INTRODUCTION
This report presents the results of our lead-based paint survey for the structure located at 887 Fulton St. in Fresno, California. The lead-based paint survey was conducted under the conditions of Krazan & Associates, Inc.’s (Krazan’s) Proposal No. P25-287, dated June 24, 2025. Dora Westerlund gave written authorization on July 3, 2025, for Krazan to proceed with the lead-based paint survey.

2.0 PURPOSE AND SCOPE OF WORK
The purpose of the lead-based paint survey was to identify and quantify the presence of potential lead- based paints (LBPs) at the on-site structure. The scope of work for the limited LBP survey included conducting a visual survey of the structure, conducting bulk sampling and analysis of materials suspected to contain lead.

3.0 BUILDING DESCRIPTION
The structure was a two-story structure with basement, stucco, brick, and ceramic tiled exterior walls, with mineral surface rolled roofing. Interior construction included gypsum board, acoustic ceiling tiles, plaster, and suspended ceilings with two-foot by four-foot ceiling panels; gypsum board, plaster, wood, brick, concrete block, open-framed, and ceramic tiled walls; and concrete floors overlain (in areas) by wall-to-wall carpeting, floor tiles, ceramic tiles, and terrazzo. 215 West Dakota Avenue  Clovis, California 93612  (559) 348-2200  FAX (559) 348-2190 With Offices Serving the Western United States
1425015 LBP

Project No. 014-25015
Page No. 2

4.0 INVESTIGATIVE METHODS

4.1 Sampling Protocols
Thirty (30) samples of suspected LBPs were collected from the on-site structure. Representative samples were collected from painted surfaces that visually appeared to contain various types of paint. Every attempt was made to identify unique paint and/or surface types. However, a chance exists that: 1) different paints are not visually distinct, 2) hidden surfaces exist, or 3) areas that were painted with different and distinct paint types are now covered by a single overlay. Sample locations for this survey were determined by the inspector and were selected in a random fashion after homogeneous areas were identified.

Sample locations for this survey were chosen in a semi-random fashion with emphasis placed on minimizing damage to the sampled materials. The samples were collected by carefully removing a small amount of the suspect material, with every attempt to separate the paint from the substrate. If possible, samples were collected from existing damaged areas or loose pieces of materials. Each sample was placed in a separate sealed plastic bag, and labeled with the project number and sample number.

4.2 Laboratory Analytical Methods
Paint chip samples were analyzed by Environmental Hazards Services of Richmond, Virginia, to detect the presence of total lead in accordance with EPA Method 7420. Copies of the analytical results and Chain-of-Custody Record are included in Appendix A.

5.0 RESULTS OF INVESTIGATION
As stated previously, 30 samples of suspected LBPs were collected from throughout the structure.

Analytical laboratory results and field observations of the materials sampled have been summarized on Table I, following the text of this report. Information presented within the table includes the sample number, the room equivalent, building component, substrate, testing location, lead content, the volume of LBP identified (typically expressed in square feet), and the condition of the material sampled. In addition, footnotes have been provided to convey pertinent information regarding the specific sample.

KRAZAN & ASSOCIATES, INC.

With Offices Serving the Western United States
1425015 LBP

Project No. 014-25015
Page No. 3
The following paints contained 0.5% or greater total lead by weight and are defined as lead-based paint:

Pink gypsum board wall – 2nd floor (Sample No. 4)
Pink wood partition wall – 1st floor (Sample No. 20)
The following paints contained greater than 0.06% total lead by weight and are defined as lead-containing paint:

Tan wood door frame – 2
nd floor (Sample No. 3)
Pink wood trim – 2nd floor (Sample No. 5)
Tan wood partition wall – 2nd floor (Sample No. 7)
Red brick wall – 2nd floor (Sample No. 8)
Yellow plaster wall – 2nd floor (Sample No. 10)
Off-white gypsum board wall – 2nd floor (Sample No. 11) Tan gypsum board wall – 2nd floor (Sample No. 12)
Off-white gypsum board wall – 1st floor (Sample No. 15) Pink gypsum board ceiling – 1st floor (Sample No. 16)
Tan gypsum board wall – basement (Sample No. 22)
Tan plaster wall – basement (Sample No. 23)
Off-white plaster wall – basement (Sample No. 24)
Tan wood door frame – basement (Sample No. 26)
The paints on the exterior and interior of the building surveyed were generally in fair condition.

6.0 CONCLUSIONS
Occupational exposure to lead is regulated by both the Federal Occupational Safety and Health Administration (OSHA) (29 CFR 1926.62) and California OSHA (Title 8, GISO 5198 and CSO 1532.1).

Based on Federal and California OSHA, when disturbing paints which contain lead (any amount of detectable lead), the above-noted OSHA and California OSHA regulations should be followed.

Furthermore, the United States Department of Housing and Urban Development (HUD) publication entitled "Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing," dated 1995, outlines specific guidelines for disrupting paint with lead in excess of 5,000 mg/kg (lead-based paint). These guidelines have been developed primarily to address conditions within buildings utilized for residential purposes. In addition, industry accepted standards also suggest that building owners notify occupants regarding the presence, location, and extent of lead-based paints. Records of all notifications and reports must be maintained for the duration of ownership and must be transferred to successive owners.

KRAZAN & ASSOCIATES, INC.

With Offices Serving the Western United States
1425015 LBP

Project No. 014-25015
Page No. 4
All construction work where an employee may be occupationally exposed to lead containing paint, including building renovation and demolition, must comply with OSHA Regulation 29 CFR 1926.62 and California OSHA Title 8, CSO 1532.1. This regulation requires initial employee exposure monitoring to evaluate worker exposure during work that disturbs lead containing paint. Krazan suggests that engineering controls and air monitoring for airborne lead be conducted at the start of projects in which worker exposure to lead containing paint is likely.

Demolition of buildings containing lead-based paint is not specifically regulated by the San Joaquin Valley Air Pollution Control District (APCD). General requirements for building demolition, however, such as dust control, must be strictly followed. Also, building components which have been identified as being coated with LBPs must be handled and disposed of as a Hazardous Waste and cannot be discarded as general construction debris.

7.0 LIMITATIONS
This survey and review of the subject property has been limited in scope. This investigation is undertaken with the calculated risk that the presence, full nature, and extent of lead-containing paints would not be revealed by visual observation and sampling alone. Krazan & Associates, Inc. makes no representation as to the lead content of paints not sampled or that were inaccessible to our inspector.

The findings of this report were based upon the results of our site inspection, paint chip sampling, along with the interpretation of paint chip analysis results. Lead-paint testing was done by a laboratory certified by the State of California Department of Public Health (DPH) and accredited as an AIHA Environmental Lead Laboratory Accreditation Program (ELLAP) laboratory. Therefore, the data are accurate only to the degree implied by review of the data obtained and by professional interpretation, and the degree of care of ensuring the testing accuracy and the representative nature of the samples obtained. The findings presented herewith are based on professional interpretation using state of the art methods and equipment and a degree of conservatism deemed proper as of this report date. It is not warranted that such data cannot be superseded by future environmental or technical developments.

This lead-based paint survey is not intended to be the sole basis of lead paint removal bids. Confirmation of specific lead-based paint and volumes should be conducted by prospective removal contractors prior to accepting removal bids. This report is provided for the exclusive use of the client noted on the cover page and is subject to the terms and conditions in the applicable contract between the client and Krazan. The KRAZAN & ASSOCIATES, INC.

With Offices Serving the Western United States
1425015 LBP

Project No. 014-25015
Page No. 5
client is the only party to whom Krazan has explained the risks involved and has been involved in the shaping of the scope of services needed to satisfactorily manage those risks, if any, from the client’s point of view. Any third party use of this report, including use by Client’s lender, prospective purchaser, or lessee will be subject to the terms and conditions governing the contractual work in the contract between the client and Krazan. The unauthorized use of, release of, or reliance on the information contained in this report, without the expressed written consent of Krazan & Associates, Inc., is strictly prohibited and will be without risk or liability to Krazan.

If you have any questions or if we may be of further assistance, please do not hesitate to contact our office at (559) 348-2200.

Respectfully submitted,
KRAZAN & ASSOCIATES, INC.

Jeffrey R. Noël
DPH Certified Lead Inspector/Assessor
LRC-00003853
JRN/mlt
KRAZAN & ASSOCIATES, INC.

With Offices Serving the Western United States
1425015 LBP

TABLE I

LEAD-BASED PAINT SURVEY RESULTS
Commercial Property
887 Fulton Street
Fresno, California
July 10, 2025 Sampling
Lead content Volume Notes/
Sample No. Sample Location Paint Sampled % by weight est. in sq. ft. Condition Additional locations 1 2nd Floor brick wall 0.0067 NC good off-white
2 2nd Floor gypsum board wall <0.0046 NC good off-white 3 2nd Floor wood door frame 0.46 NC good tan
4 2nd Floor gypsum board wall 0.74 400 good pink
5 2nd Floor wood trim 0.30 NC good pink
6 2nd Floor gypsum board wall <0.0047 NC good tan
7 2nd Floor wood partition wall 0.010 NC good tan
8 2nd Floor brick wall 0.27 NC good red
9 2nd Floor gypsum board ceiling <0.0045 NC poor pink
10 2nd Floor plaster wall 0.10 NC poor yellow
11 2nd Floor gypsum board wall 0.23 NC good off-white
12 2nd Floor gypsum board wall 0.44 NC good tan
13 1st Floor plaster wall <0.0048 NC good tan
14 1st Floor gypsum board ceiling 0.0086 NC poor tan
15 1st Floor gypsum board wall 0.14 NC good off-white
16 1st Floor gypsum board ceiling 0.039 NC good pink
17 1st Floor gypsum board wall <0.0045 NC good green
18 1st Floor wood door frame <0.0041 NC good off-white
19 1st Floor gypsum board wall 0.0051 NC good off-white 20 1st Floor wood partition wall 1.3 200 good pink
21 1st Floor gypsum board wall <0.0043 NC good off-white 22 Basement gypsum board wall 0.087 NC good tan
23 Basement plaster wall 0.043 NC good tan
24 Basement plaster wall 0.22 NC poor off-white
25 Basement gypsum board wall <0.0046 NC fair tan
26 Basement wood door frame 0.47 NC good tan
27 Basement concrete wall 0.0055 NC good tan
28 Basement gypsum board ceiling <0.0044 NC good tan
29 Exterior metal framing <0.0047 NC good green
30 Exterior brick wall <0.0040 NC good green
NOTE: Lead-based paint is defined as paint containing 0.5% or greater lead by weight. NC = Not calculated Lead containing paint is defined as paint containing greater than 0.06% lead by weight.

Bold text items are considered Lead-based paint Italic text items are considered Lead-containing paint KRAZAN & ASSOCIATES, INC.

Serving the Western United States 1425015 LBP
10 8
9 12
11 29
16 30
15 13 14
26 24 25
23 22

EXPLANATION

PAINT SAMPLE LOCATION
7 21
20 27
4 5
6 19
28 3 2
1 18 17
Second
Floor
First
Floor
Basement
Level

FLOOR PLAN WITH

PAINT SAMPLE LOCATIONS

COMMERCIAL PROPERTY
887 FULTON MALL

FRESNO, CALIFORNIA
Scale:

NOT TO SCALE
Date:
7 / 25
Drawn by:

J. R. N.

Approved by:

J.R.N
Project No.
0 14-25015
Figure No.
1 Appendix A
Lead Paint Chip
Analysis Report
7469 Whitepine Rd
North Chesterfield, VA 23237
Telephone: 800.347.4010 Report Number: 25-07-02051
Client: Krazan & Associates Inc. Received Date: 07/11/2025 215 West Dakota Ave Analyzed Date: 07/18/2025
Clovis, CA 93612 Reported Date: 07/18/2025
Project/Test Address: 014-25015; Commercial Property; 887 Fulton Street Collection Date: 07/10/2025
Client Number: Fax Number:

Laboratory Results05-5650 559-348-2201
Lab Sample
Number
25-07-02051-001
Client Sample
Number
1 Collection Location Pb (ug/g)
ppm
67 % Pb by
Wt.

0.0067
Narrative
ID
25-07-02051-002 2 <46 <0.0046
25-07-02051-003 3 4600 0.46
25-07-02051-004 4 7400 0.74
25-07-02051-005 5 3000 0.30
25-07-02051-006 6 <47 <0.0047
25-07-02051-007 7 100 0.010
25-07-02051-008 8 2700 0.27
25-07-02051-009 9 <45 <0.0045
25-07-02051-010 10 1000 0.10
25-07-02051-011 11 2300 0.23

Page 1 of 3 ends

Environmental Hazards Services, L.L.C
Client Number: 05-5650 Report Number: 25-07-02051
Project/Test Address: 014-25015; Commercial Property; 887 Fulton Street Lab Sample Client Sample Collection Location Pb (ug/g) % Pb by Narrative Number Number ppm Wt. ID
25-07-02051-012 12 4400 0.44
25-07-02051-013 13 <48 <0.0048
25-07-02051-014 14 86 0.0086
25-07-02051-015 15 1400 0.14
25-07-02051-016 16 390 0.039
25-07-02051-017 17 <45 <0.0045
25-07-02051-018 18 <41 <0.0041
25-07-02051-019 19 51 0.0051
25-07-02051-020 20 13000 1.3
25-07-02051-021 21 <43 <0.0043
25-07-02051-022 22 870 0.087
25-07-02051-023 23 430 0.043
25-07-02051-024 24 2200 0.22
25-07-02051-025 25 <46 <0.0046
25-07-02051-026 26 4700 0.47
25-07-02051-027 27 55 0.0055
25-07-02051-028 28 <44 <0.0044
25-07-02051-029 29 <47 <0.0047

Page 2 of 3 ends

Environmental Hazards Services, L.L.C
Client Number: 05-5650 Report Number: 25-07-02051
Project/Test Address: 014-25015; Commercial Property; 887 Fulton Street Lab Sample Client Sample Collection Location Pb (ug/g) % Pb by Narrative Number Number ppm Wt. ID
25-07-02051-030 30 <40 <0.0040
Sample Narratives:

Preparation Method: ASTM E-1979-17
Analysis Method: EPA SW846 7000B
Reviewed By Authorized Signatory:

Melissa Kanode
QA/QC Clerk
The Reporting Limit (RL) for samples prepared by ASTM E-1979-17 is 10.0 ug Total Pb. The RL for samples prepared by EPA SW846 3050B is 25.0 ug Total Pb. Paint chip area and results are calculated based on area measurements determined by the client. All internal quality control requirements associated with this batch were met, unless otherwise noted.

The condition of the samples analyzed was acceptable upon receipt per laboratory protocol unless otherwise noted on this report. Results represent the analysis of samples submitted by the client. Sample location, description, area, etc., was provided by the client. Results reported above in mg/cm3 are calculated based on area supplied by client. This report shall not be reproduced except in full, without the written consent of Environmental Hazards Services, L.L.C.

ELLAP Accredtitation through AIHA LAP, LLC (100420), NY ELAP #11714.

LEGEND Pb= lead ug = microgram ppm = parts per million
ug/g = micrograms per gram Wt. = weight

Page 3 of 3 ends

ENVIRONMENTAL HAZARD SERVICES, L.L.C.
7469 WHITE P|NE ROAD - RTCHMOND, VA 23237 PHONE (804)27s4788 FAx(804) 275-4907

CHAIN OF CUSTODY FORM
Company Name: Krazan & Associates, lnc. Date: 7t'10t2025 Address: 215 West Dakota Avsnue Contact Name: Jeff Nodl City, State, Zip: Clovis, CA 93612 Sampler Name: Jeff Nodl EHS Client Account #: 5-5650 D Project #: 014-2501 5
Phone #: (559) 348-2200 FAX (559) 348-2201 Commercial Property 887 Fulton Street
P.O. #
25-07-02051
Other Metals Particulate: Total NuAsbestos Lead (Specify metals below) Re .Y ililililtiltililllilllililililililililil|il1|il1|il1il1|il c C a tu .9 Due Date:f ro
Sample Sample Oale oo a za @ o o 07t1812025J o o, tLNumber & Time & o I() E tu o Ec) E f .o -o c (l,
tt! a & o, ao .o C,
oE t! 6 Air Volume (L) (Friday)
(DiI I E s =t! E o- I t c', OR Wipe ELo (L o o c(L (!c c o 5 'x Area (fi2) oR= .E o- J (, JJ tx uJ (tr o o=f -J = 6 o o o (D o- tL (I F F (L (L (L a F F - F 3 F Scrape Area (cm2) 1 7t'1ot2025 X XIIII II
2 7t10t2025 X XIIII III II --rt--3 7l'to12025 X XIIII II 4 711012025 X XIIII II IIIIITI
5 7t10t202s X XIIII II TIIITII
6 7110t2025 X XIIII IT
7 7110t2025 X xITII II
8 7t10t2025 X xIITT II IIIIIII
I 7t1012025 X XII II IIIIIII
10 7t1012025 X X
I
IIIII
II
IrIIII
I
III
II
rII
III
I
I
III
II
I
II
I
I
I
I
II
IIII
IIII
II
II
IIII
r
I
I
IIIIII
I
III
III
II
III

II IIIIIII
11 7t10t202s X xII II IIIIIII
7t10t2025 X XII II IIIIIII
13 7t10t2025 X XII II II IIIIIII
14 7110t2025 X XrI II II IIIIIII
15 7t10t2025 X XIT II rI IIIIIII
16 7t1012025 X XII II II IIIIIII
17 7t10t2025 X XII II II IIIIITI
18 7t10t202s X XII II II IIIIIIT
19 7t10t2025 X XII II II IIIIIII
20 7t10t2025 X XII I II IIITIII*Dowi sam es submitted meet ASTM E'l792 irements? Yes No Released Jeff Noel Si nature Date /6 .r-(-
Received By:l Signature Dale:J /, , /n r rt n t1 O
ENVIRONMENTAL HAZARD SERVICES, L.L.C.
7469 WHTTE prNE ROAO - R|CHMONO, VA 23237 PHONE (804J 275-4788 FAX (804)27s-4907

CHAIN OF CUSTODY FORM
Company Name: Krazan & Associates, lnc. Date: 7t10t2025 Address: 215 West Dakota Avenue Contact Name: Jeff Nodl City, State, Zip: Clovis, CA 93612 Sampler Name: Jeff Noel EHS Client Account # 15650 D Proiect #: nl L)\nl\
Phone #: (s59) 348-2200 FAx: (559) 348-2201 Commercial Propertv 887 Fulton Street
P.O. #: Page 2 of 2
Other Metals Particulate Total Nuisance (NIOSH 0500)Asbestos Lead (Specify metals below) Respirable (NIOSH 0600) c C (, _qf =c)
J o o= o ! z o oSample Sample Date =
c o @
E o-Number & Time IL q, o E o E(., (, o,v. {, t f Air Volume (L) Comments -o p
LL
c (! ul (! (I E, U) -o GI
o t!
(tr
oI E s (I o- B t OR WipeE o,o (L o clt(L (Lc
7110t2025 X X

IIIIII II II II III
: o ,q tuo. J (n J E ,9 Area (fl2) oR
l (L J J II ul '6 o '6 o o o od) (L IL F F (L o- o- a F ts F F Scrape Area (cm2) 2'l 7t10t2025 X X =IIIIII II rI II IIIIITIII II II II
=
III
23 7t10t2025 X X
IIIIII II II II III24 7t10t2025 X X
IIIIIT II II II III25 7t10t2025 X X
IIIIII II II II III26 7t'1ot2025 X x

IIIIII II II II III
II
II
II
II
711012025 X X
IIIIII II II II III2A 7t10t2025 X X
IITIII II II II III7110t2025 X X,o
IIITII II II II III30 7 t10t2025 X X
IIIIII II II II IIIIIIIII II II II IIIrI
I

IIII IIIIIIII II III

IIIIII II II II IIIIIIIII IT II II III
IIII IIIIIIII II IIIIIII IIIIIIII II IIIIIII IIIIIIIT II IIIIIII IIIIIIII II IIIIIII IIIIIIII II III*Oo 0e samD les submitted meet ASTM E1792 uirements? Yes No- ,/Released By Jeff Noel S nature oate: Z/t./^z- Received By: l- llt n,^. r.,,. kr ,/.-p n r L / Signature: 1l Dats: -.-t /r, /'\ r )-t A..- Appendix B

APPENDIX D - Cost Estimate
for Alternatives 2 and 3

Preliminary Opinion of Probable Cleanup Costs Analysis of Brownfield 10/3/2025 Cleanup Alternatives - 887 Fulton Street, Fresno, CA
Description Quantity Unit Unit Cost Cost Notes/Assumptions Alternative 2 - Encasement / Enclosure
Contractor mobilization/demobilization 1 LS $ 12, 500.00 $ 12,500 Subcontractor Bid Permitting 1 LS $ 5, 000.00 $ 5,000 Project experience
Site Preparation and Security fencing 1 LS $ 7, 500.00 $ 7,500 Project experience Removal of all interior finishes to expose stucture 1 LS $ 331, 500.00 $ 331,500 Subcontractor Bid Limited Asbestos Abatement 1 LS $ 100, 000.00 $ 100,000 Does not remove all ACMs from building Limited Roof Repair 1 LS $ 50, 000.00 $ 50,000 Project experience Third Party clearance sampling/oversight 3 Week $ 17, 500.00 $ 52,500 Subcontractor Bid Operations and Maintenance Requirements 30 Year $ 1, 500.00 $ 45,000 Assumed to require $1,000 in annual maintenance and $500 in annual notification requirements
Closure Reporting 1 LS $ 10, 000.00 $ 10,000 Project experience Alternative Subtotal $ 614,000
Contingency 10%
Alternative Total $ 675,400
Alternative 3 - Full Abatement
Contractor mobilization/demobilization 2 LS $ 12, 500.00 $ 25,000 Subcontractor Bid Permitting 1 LS $ 5, 000.00 $ 5,000 Project experience
Site Preparation and Security fencing 1 LS $ 7, 500.00 $ 7,500 Project experience Asbestos abatement 1 LS $ 488, 300.00 $ 488,300 Subcontractor Bid Removal of all interior finishes to expose stucture 1 LS $ 95, 000.00 $ 95,000 Subcontractor Bid Roof Replacement 1 LS $ 350, 000.00 $ 350,000 Project experience + 40% contingency Third Party clearance sampling/oversight 6 Week $ 17, 500.00 $ 105,000 Subcontractor Bid Closure Reporting 1 LS $ 10, 000.00 $ 10,000 Project experience Alternative Subtotal $ 1,085,800
Contingency 10%
Alternative Total $ 1,194,400
\\us0318-ppfss03\shared_projects\203724380\203724380 Fresno Supp RLF\05_report_deliv\deliverable\Berkeley Bldg\ABCA\Appendix D_tbl_887 Fulton Street)_ABCA_DRAFT_20250926.xlsx

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