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HomeMy WebLinkAboutCorrespondenceDave Argo From: Dave Argo Sent: Wednesday, January 9, 2019 4:49 PM To: 'viccol Ou corrrcas1.rre1' Subject: New Steel Structure - Permit #BLRE-12-18-5600 Attachments: Vicco Site Plan Redlines.pdf Glenn: We have been reviewing your application to construct at new steel building at 45755 Highway 6 in Canyon Creek. Unfortunately, based on information included in your submitted plans, there are several issues which must be addressed and/or revised to meet Garfield County requirements before we can issue a building permit for this project. Items that must be addressed include the following: 1. Setback Encroachment — Placement of the new building does not comply with County setback requirements of 50 feet at the front yard (along Highway 6 & 24). As currently shown on the Site Plan prepared by Bookcliff Surveying, this distance is only 20'-4" and the dimension appears to be incorrectly taken from edge of asphalt — not the highway right of way which is shown on the site plan to be approximately 15 feet further onto the subject property. The required 50 -foot front yard setback is properly measured from the right-of-way, and will effectively reduce the available building footprint size for the proposed building by about 40 feet (+/-) in length. (see attached PDF) 2. Proposed Use of New Building — Please confirm that use of this new building is for personal (not commercial) use and it will only include uses typically considered as accessory to single-family residential properties. Also please confirm whether the building will serve as a motor vehicle repair garage, or if it's intended for private garage/storage use. 3. Soils Report — Please submit a digital copy of the soils report by HP -Kumar as referenced on the Engineered foundation plans. 4. Septic System — The Site Plan references a proposed septic system, but no septic permit application has been included. Please verify whether a septic system will be included as part of the construction of this new building, and submit a septic permit application if applicable. 5. Adjacent Existing Building — As illustrated on the Site Plan the new building will be built right up against an existing outbuilding, which raises several issues: a. How will the existing structure and/or foundation be protected and/or integrated into the new proposed building? If the new building's foundation is located directly up against to the existing building, provide structural details for how the two structures will be joined together. b. Is it the intent that the existing building will be joined together with a common door access provided between the new and existing structures? Or will it remain independent from the new structure? c. Provide a description of use(s) within the existing building. Please provide us with follow-up to these outstanding issues so that we can finalize our review and issue a building permit as quickly as possible. In the meantime, we will set aside your plans in our "pending" files until we have received a response from you about these items. Thank you for your assistance — Dave Argo Plans Examiner CA.;. Garfield County Community Development Department 1 Proposed RV Barn Edge ge LT. . Highway 6& 24 Dave Argo From: Dave Argo Sent: Thursday, February 21, 2019 8:45 AM To: 'Bart and Jennifer VICTOR' Cc: Tricia Parish; Glenn Hartmann Subject: RE: variance meeting and building permit - 45755 Highway 6 Bart & Jennifer: Please see my responses in RED TEXT below to your questions. Dave Argo Plans Examiner Garfield County I Community Development Department 108 8th Street, Suite 401 Glenwood Springs, CO 81601 Tel: 970-945-8212 Ext. 1610 Email: dargo@garfield-county.com Web: garfield-county.com From: Bart and Jennifer VICTOR [mailto:viccol@comcast.net] Sent: Wednesday, February 20, 2019 3:40 PM To: Dave Argo Cc: viccol@comcast.net Subject: variance meeting and building permit - 45755 Highway 6 Hi, Dave. Bart just talked to our engineer, Vern Brock. Vern said that he talked to you today. Vern is under the impression that we need to have revised building plans to you by tomorrow in preparation for the variance meeting on Monday. The push to have the plans to you by tomorrow at noon is because you are out of the office on Friday. The push to have the plans doesn't make sense for the variance meeting. We understand that you will need the plans before the building permit is issued, but it doesn't make sense that the plans need to be completed before the meeting. If the variance isn't approved, it just seems that we are throwing money away on work that we can't use. Our question is whether or not you need plans before the variance meeting. I agree with you on this. Based on my conversation with Tricia yesterday, I believe that she was trying to convey to Vern that the most expeditious way to obtain the building permit is to have all additional design work completed for submittal immediately following the BOA meeting. If it were me, I would also await the outcome of the BOA meeting prior to authorizing the Structural Engineer to proceed with design modifications to the original steel building plans, because there is always a possibility that your variance request is denied by BOA. 1 Attached is the site plan that Bookcliff completed and is in our file with Tricia Parish and in the variance application. Is this sufficient for our building permit or are you asking for a new site plan? Was the site plan you referenced with Vern ono that is supposed to be completed after construction? Will we have to do another one? The attached (revised) site plan — and approval of your variance request by the BOA — will be adequate for the building permit application. When the amended building plans are submitted for building permit, please also include (2) copies of this revised site plan from Bookcliff Surveying. We met with Vern on Monday, and he said that he was going to ask you if detailed modifications to the existing plans to omit one of the 20' sections would be acceptable to Garfield County in lieu of all new drawings. Assuming that the attached site plan is sufficient and that we get approved on Monday night for our variance, the remaining items for our building permit application are revised building plans and specific detail on how the foundation and building connect which was detailed in your email from January 9 (text below). Per my phone conversation with Vern yesterday, we will require updated Engineered foundation plans and modified steel building plans be submitted that properly illustrate the revised (smaller) footprint as shown on the new site plan. In addition, we will require inspection sign -offs by the Structural Engineer (Vern) for foundation and structural steel frame of the building — in lieu of our more typical building inspections. This is because the original steel frame building as designed by General Steel Corp. is now being redesigned by Vern Brock. He will therefore be assuming additional responsibility and liability by verifying to the Building Dept. that construction meets his design engineering intent. 5.Adiaeent Existing Building— As illustrated on the Site Plan the new building will be built right up against an existing outbuilding, which raises several issues: a.How will the existing structure and/or foundation be protected and/or integrated into the new proposed building? If the new building's foundation is located directly up against to the existing building, provide structural details for how the two structures will be joined together. b.Is it the intent that the existing building will be joined together with a common door access provided between the new and existing structures? Or will it remain independent from the new structure? c.Provide a description of use(s) within the existing building. Bart has a call in to you, but we thought that this email may be a little clearer to explain our questions. Thanks, Jennifer 2 a.How will the existing structure and/or foundation be protected and/or integrated into the new proposed building? If the new building's foundation is located directly up against to the existing building, provide structural details for how the two structures will be joined together. b.Is it the intent that the existing building will be joined together with a common door access provided between the new and existing structures? Or will it remain independent from the new structure? c.Provide a description of use(s) within the existing building. Bart has a call in to you, but we thought that this email may be a little clearer to explain our questions. Thanks, Jennifer 2 Dave Argo From: Bart and Jennifer VICTOR tvicco1 @comcast.net? Sent: Wednesday, February 20, 2019 3:40 PM To: Dave Argo Cc: viccol@comcast.net Subject: variance meeting and building permit - 45755 Highway 6 Attachments: 15062-01 Site Plan update 2019-01-18.pdf Follow Up Flag: Follow up Flag Status: Flagged Hi, Dave. Bart just talked to our engineer, Vern Brock. Vern said that he talked to you today. Vern is under the impression that we need to have revised building plans to you by tomorrow in preparation for the variance meeting on Monday. The push to have the plans to you by tomorrow at noon is because you are out of the office on Friday. The push to have the plans doesn't make sense for the variance meeting. We understand that you will need the plans before the building permit is issued, but it doesn't make sense that the plans need to be completed before the meeting. If the variance isn't approved, it just seems that we are throwing money away on work that we can't use. Our question is whether or not you need plans before the variance meeting. Attached is the site plan that Bookcliff completed and is in our file with Tricia Parish and in the variance application. Is this sufficient for our building permit or are you asking for a new site plan? Was the site plan you referenced with Vern one that is supposed to be completed after construction? Will we have to do another one?? We met with Vern on Monday, and he said that he was going to ask you if detailed modifications to the existing plans to omit one of the 20' sections would be acceptable to Garfield County in lieu of all new drawings. Assuming that the attached site plan is sufficient and that we get approved on Monday night for our variance, the remaining items for our building permit application are revised building plans and specific detail on how the foundation and building connect which was detailed in your email from January 9 (text below). 5.Adjacent Existing Buildi As illustrated on the Site Plan the new building will be built right up against an existing outbuilding, which raises several issues: 1 SITE PLAN Rebar and Cap LS No. 11204 d�Power Pole and Right -of -Way Marker S 87 °03'00 ' W -127.70' s — — — D °53'54" U.S. Highway 6 & 24 R 5989.60' Edge of Asphalt L 93.91' _ — — Book 391, Page 45 1-70 / D 8°13'11" R 1186.00' L 170.15' CBS 68°22'00" W CH 170.00' 1 SCALE: 1 "= 40' PROPERTY DESCRIPTION A TRACT OF LAND SITUATE IN THE W1/2NW1/4, SECTION 36, T. 5 S., R. 90 W. OF THE 6TH P.M. DESCRIBED AS FOLLOWS: BEGINNING ATA POINT ON THE NORTHERLY RIGHT OF WAY LINE OF U.S. HIGHWAY 6 & 24 WHENCE THE NORTHWEST CORNER OF SAID SECTION 36 BEARS N. 42 DEGREES 41' W. 2074.72 FEET; THENCE SOUTHWESTERLY 170.83 FEET ALONG THE NORTHERLY RIGHT OF WAY LINE OF U.S. HIGHWAY NO. 6 & 24 ON A 4 DEGREES 50' CURVE TO THE LEFT WITH A RADIUS OF 1186 FEET (THE CHORD OF THIS ARC BEARS S. 68 DECREES 22' W. 170.0 FEET) TO THE CENTER OF CANYON CREEK; THENCE N. 30 DEGREES 27' 240.10 FEET ALONG THE CENTER OF CANYON CREEK; THENCE N. 57 DEGREES 34' E. 138.40 FEET; THENCE N. 64 DEGREES 50' E. 138.93 FEET;; THENCE S. 7 DEGREES 38' E. 280.10 FEET TO THE NORTHERLY RIGHT OF WAY LINE OF U.S. HIGHWAY NO. 6 & 24, THE POINT OF BEGINNING. COUNTY OF GARFIELD, STATE OF COLORADO NOTES 1.) DATE OF SURVEY WAS JANUARY 16, 2019 . 2.) THIS SURVEY IS BASED ON WARRANTY DEED RE:CEORDED NOVEMBER 21, 2018 AS RECEPTION NO. 914419 AND LAND TITLE GUARANTEE COMPANY ORDER NO. GW63013150 DATED NOVEMBER 21, 2018. 3.) THE CURRENT LEGAL DESCRIPTION DOES NOT EXCEPT THE PROPERTY DESCRIBED IN BOOK 391 AT PAGE 45 THAT WAS CONVEYED TO CDOT IN 1959. SURVEYOR'S STATEMENT I, MICHAEL J. LANGHORNE, A REGISTERED LAND SURVEYOR, LICENSED UNDER THE LAWS OF THE STATE OF COLORADO DO HEREBY CERTIFY THAT THE SURVEY SHO g.. ,',i WAS PREPARED ON THIS DATE JANUARY 16, 2019 BY ME OR Cl w;; ER VISION AND CHECKING THAT THIS MAP IS A TRUE R U"' d y "v:i :572 r:. MI ++ + LANGHORNE, BOOK FOR t kBEHALF OF , t� Fir PA R 1710 41 1A11� � IP DO REGISTRATION NO. 36572 NC. Lu 2 O re N cry 0'° 5m = N Jn00 FII£: 2112019 TL DMZ = 1/17/IL PROJECT NO, 15062-D1 SHEET 1 OF 1 Dave Argo From: Tricia Parish Sent: Tuesday, February 26, 2019 7:55 AM To: Dave Argo; Vern Brock Cc: Bart and Jennifer VICTOR Subject: RE: variance meeting and building permit - 45755 Highway 6 Hi Dave, The variance was approved/signed at last night's Board of Adjustment hearing. Conditions of the Resolution that was signed: A. The forgoing Recitals are incorporated by this reference as part of the resolution. B. The Vicco's II, LLC Front Yard Setback Variance Request is hereby approved subject to compliance with the following conditions: 1. That all representations made by the Applicant in the application shall be conditions of approval unless specifically altered by the conditions of approval. 2. The variance is granted for the proposed storage building construction only as detailed on the site plan. The storage building shall maintain a minimum setback of at least 25 ft. from the edge of the right-of-way of Highway 6 & 24. 3. That access to the storage building shall utilize the existing main driveway access to the site and single family residence, with no direct access from the storage building onto Highway 6 & 24 permitted. 4. The new construction shall comply with all Building Code requirements, including the 2015 Building Codes for personal (non-commercial) use. From: Dave Argo Sent: Monday, February 25, 2019 1:43 PM To: Vern Brock <vern.brock@townofeagle.org> Cc: Tricia Parish <tparish@garfield-county.com>; Bart and Jennifer VICTOR <viccol@comcast.net> Subject: RE: variance meeting and building permit - 45755 Highway 6 Vern: Got the plans that you had dropped off this morning & gave a copy to Tricia preceding tonight's BOA mtg. for her review. I won't review until a decision is made by the BOA. Our typical turnaround for amended plans submittals is 3 — 5 business days and I don't foresee any problems getting out by end of week — pending BOA approvals are all in place and without other extenuating circumstances, of course. Thanks, Dave Argo Plans Examiner 1 Dave Argo From: Dave Argo Sent: Thursday, February 28, 2019 11:34 AM To: 'vern@brockcivil.com'; 'Bart and Jennifer VICTOR' Cc: Andy Schwaller (aschwaller@garfield-county.com); Glenn Hartmann Subject: Vicco's Steel Building - Permit #BLRE-12-18-5600 Vern: After our preliminary review of plans you have submitted for Bart Victor's new steel building that will be erected at 45755 Highway 6 & 24, we cannot approve for a building permit at the present time. I tried calling you this morning to discuss, but your voicemail mailbox is full and not accepting additional messages. From the Building Department's perspective, these plans are incomplete and missing critical information for design of the foundation and attachment of the new steel building to the existing adjacent shop building. In addition, we require a letter from the building manufacturer — General Steel Corporation — clearly stating that their structure will accommodate the proposed modifications to the original building design caused by shortening it up by 20 feet to fit within required setbacks on this property. We believe that the proposed size reduction of the original building has consequences for structural loading of the new, smaller footprint and we have no indication that this issue has been addressed to the satisfaction of the steel building manufacturer. Drawings that Bart originally submitted for this project included the following information which is in line with the Building Department's expectations for a manufactured steel building: • Steel Building Plans — typically prepared by the manufacturer. • Foundation Plan, Details & Specifications — often times prepared by a local or independent Structural Engineer which fits the manufacturer's requirements onto the specific site. • Structural Engineer's Calculations for loads, reactions and sizing of base plates and foundations located below the steel building frame. In contrast, the drawings that you have submitted for the revised (smaller size) building do not provide us with the level of information which we require before issuing a building permit. Please provide this requested information at your earliest opportunity — as well as a letter of verification from General Steel Corporation signing off on the proposed revisions to their manufactured building — so that we can finalize our review and issue a building permit for this project. Thank you for your assistance — Dave Argo Plans Examiner ►1,. Garfield County Community Development Department 108 8th Street, Suite 401 Glenwood Springs, CO 81601 Tel: 970-945-8212 Ext. 1610 Email: dargo@garfield-county.com Web: garfield-county.com 1 Dave Argo From: Dave Argo Sent: Monday, March 4, 2019 10:24 AM To: 'vern@brockcivil.com' Cc: 'Bart and Jennifer VICTOR'; Andy Schwaller (aschwaller@garfield-county.com) Subject: RE: Vicco's Steel Building - Permit #BLRE-12-18-5600 Vern: That's good to hear that our office will be receiving an updated package from General Steel and S.E. Consultants which provides both the steel building and the foundation design for the correctly sized building. In addition, any site specific modifications to these drawings will also need to be wet -sealed by a Colorado licensed P.E. — and it sounds like you will be serving in this role. Some of these items may include: a. Foundation and/or roof design where the new steel building & existing shop building abut one another b. Openings cut into the end wall where new steel building abuts the existing shop building c. Finish grade elevation change between the two buildings and its impact on foundation design of new building Rather than you marking up the drawings from either General Steel or S.E. Consultants and then re -stamping with your own wet -seal, our office would prefer that you submit separate drawings/details for these site specific items. We also realize that other unanticipated minor modifications may need to occur in the field, and we can work with you on that type of revisions. But any substantive deviations from the original steel building plans or S.E. Consultants plans may require additional sign -offs from them. Hope this information helps you to finalize the amended drawings to be submitted to our office. Dave Argo Plans Examiner C. Genf. ie!d i ouno• Community Development Department 108 8th Street, Suite 401 Glenwood Springs, CO 81601 Tel: 970-945-8212 Ext. 1610 Email: dargo@garfield-county.com Web: garfield-county.com From: vern@brockcivil.com [mailto:vern@brockcivil.com] Sent: Monday, March 4, 2019 7:27 AM To: Dave Argo Cc: 'Vern Brock' Subject: RE: Vicco's Steel Building - Permit #BLRE-12-18-5600 Dave, It is Victor's intent to engage General Steel to revise their plans for a 60' x 80' building, and likewise to update the SE Consultants "boiler plate" foundation design and calcs to match. With that, I will be engaged to design a foundation that fits the site topo, the adjoining parts to the existing structure, and a site plan that shows access, grading. Because the building package that is sitting on the ground right now is a 60' x 100' building, who signs off on the modifications to that building for the final foundation since it is not General Steel and not SE Consultants ? I am just trying to understand my liability and with new calcs and a boiler plate foundation, are all the problems really solved? Thanks Vervt L. grog, P.E. Brock Civil, LLC vern(brockcivil,com P.O. Box 3644 Eagle, CO 81631 Dave Argo From: Bart and Jennifer VICTOR <viccol @comcast.net> Sent: Thursday, March 7, 2019 11:47 AM To: Dave Argo Cc: Andy Schwaller; viccol@comcast.net; Tricia Parish Subject: RE: Vicco's Steel Building - Permit #BLRE-12-18-5600 Hi, Dave. Bart left you a message yesterday. We are trying to evaluate where we are in this process and have some questions. We were surprised to learn that we needed entirely new plans from General Steel. Even our erector was under the impression that detailed modification notes to the original plans would suffice. We have ordered modified plans from General Steel; they are about 4 weeks out. We are pushing them to complete faster, but there are no guarantees that we can get this done. If it takes more than 2 weeks, we have lost our erector until the fall. Is there anything that we can do in advance of the building permit to get ready for construction? We are really concerned about the issues raised with Vern's submissions to you. We are considering making a change in our engineer. From our perspective, things started to really get muddled once Vern stepped in. We haven't seen any of the drawings that were submitted. Based on what you have seen, are we foolish to start with a new engineer this far into the process? Do Vern's drawings just require a bit of tweaking to satisfy what Garfield County needs or are they totally insufficient? Is there anything else besides the imteized list below that we should be working on while we are waiting for the modified plans? We want to make sure that we have everything in order once we do get the plans, so hopefully, we can get this building up before April. Thanks, Bart and Jennifer Dave Argo From: Andy Schwaller Sent: Thursday, March 7, 2019 12:35 PM To: Bart and Jennifer VICTOR; Dave Argo Cc: Tricia Parish Subject: RE: Vicco's Steel Building - Permit #BLRE-12-18-5600 Dave is in Denver until Monday. Anytime a set of sealed drawing are submitted, the engineer must be notified to change the drawings if there are changes during the job. Changes in one part of the structure affects other parts of the structure. Depending on the changes, sometimes a letter or additional drawings to supplement what was submitted sealed by the original engineer is enough. In this case both the building and foundation are being changed. The original building and foundation engineers need to address the changes and submit amended plans with enough detail so guys in the field know what to build. I think Vern attempted to do the job of the above design professionals in a kind of cut and paste form which may not have been the best approach. There are still some uncertainties in the field on how to build the new structure so close to the existing structures. A local engineer in concert with the original engineers could be utilized to do this. We do have a grading permit that allows the excavation for the foundation to begin. Once we have a final foundation design, this permit could be issued at the owner's risk pending the complete building permit issuance. Rebar can be set but the concrete cannot be poured until the building permit is in place. Andy From: Bart and Jennifer VICTOR [mailto:viccol@comcast.net] Sent: Thursday, March 07, 2019 11:47 AM To: Dave Argo <dargo@garfield-county.com> Cc: Andy Schwaller <aschwaller@garfield-county.com>; vicco1@comcast.net; Tricia Parish <tparish@garfield- county.com> Subject: RE: Vicco's Steel Building - Permit #BLRE-12-18-5600 Hi, Dave. Bart left you a message yesterday. We are trying to evaluate where we are in this process and have some questions. We were surprised to learn that we needed entirely new plans from General Steel. Even our erector was under the impression that detailed modification notes to the original plans would suffice. We have ordered modified plans from General Steel; they are about 4 weeks out. We are pushing them to complete faster, but there are no guarantees that we can get this done. If it takes more than 2 weeks, 1 we have lost our erector until the fall. Is there anything that we can do in advance of the building permit to get ready for construction? We are really concerned about the issues raised with Vern's submissions to you. We are considering making a change in our engineer. From our perspective, things started to really get muddled once Vern stepped in. We haven't seen any of the drawings that were submitted. Based on what you have seen, are we foolish to start with a new engineer this far into the process? Do Vern's drawings just require a bit of tweaking to satisfy what Garfield County needs or are they totally insufficient? Is there anything else besides the imteized list below that we should be working on while we are waiting for the modified plans? We want to make sure that we have everything in order once we do get the plans, so hopefully, we can get this building up before April. Thanks, Bart and Jennifer Dave Argo From: Bart and Jennifer VICTOR <viccol @comcast.net> Sent: Thursday, March 28, 2019 11:14 AM To: Dave Argo Cc: Andy Schwaller; Tricia Parish Subject: plans for 45755 Highway 6 Attachments: 45755 Hwy 6 building plans 60x80.pdf; 45755 Hwy 6 foundation 60x80-1.pdf; 45755 Hwy 6 foundation 60x80-2.pdf Follow Up Flag: Follow up Flag Status: Flagged Hi, Dave. Revised plans from General Steel arrived this week for the building and foundation. They are attached. We are working with SGM to get the engineering for the attachment of the 2 buildings. Hopefully, we are getting closer to the front of the line with them. Thanks, Jennifer 1 *The following email was received on April 9, 2019 Subject: Bart Victor- 45755 Hwy 6&24 Name: Jaimal Proctor Email: Jairnalppsgm-inc.com Phone Number: (970) 384-9074 Message: Hello Mr. Argo, I'm with the structural department of SGM. We're trying to help Bart Victor get his metal building built. To accomodate the set back variance we've gone back and forth with Bart and his subcontractors to make a workable plan, that entails erecting the building as close as possible to his existing garage. I'm meeting with him on site at 10 tomorrow and would like to get some info from you regarding what you'd like to see for permitting_ The goal is to shore up the existing building's foundation, and pour a footing and retaining wall assembly that will allow the new building to be 3' below grade at the existing building. Would you be availble tomorrow at around 9 am for a brief meeting with me to discuss what SGM needs to provide? Currently Bart has agreed to having SGM re -design the metal building's foundation to accomodate the desired outcome. Thank you, Jaimal Proctor Jim Wilson From: Bart and Jennifer VICTOR <viccol@comcast.net> Sent: Wednesday, August 28, 2019 10:39 AM To: Jim Wilson Subject: [External] Fwd: RE: Picture -M22559 Attachments: hole in web.pdf Hi, Jim. Attached is the note from General Steel about the holes in the building. Bart's number is 303-570- 1157 if you need to reach him. Thanks, Jennifer Original Message From: Sam Clement <sam.c@Gensteel.com> To: 'Bart and Jennifer VICTOR' <viccol@comcast.net> Cc: Jonah Goldman <jonahg@Gensteel.com> Date: August 28, 2019 at 9:41 AM Subject: RE: Picture -M22559 Bart, Engineering sent me an attachment for acceptable hole spacing. Thanks Sam From: Bart and Jennifer VICTOR [mailto:viccol@comcast.net] Sent: Tuesday, August 27, 2019 3:10 PM To: Sam Clement Subject: Picture 1 Hi, Sam. Attached is a picture of where we drilled holes for conduit. Also attached is page 12 of the plans; I circled where these holes were drilled. GarCo just needs an okay from an engineer on this. Sounded like an email would work. Let me know if this works or if you need more information from us. Thanks, Jennifer 2 16 HOLE IN WEB SMALL HOLES "D"=24) MAX. icif p O.K. TO DRILL 2" MAX. HOLES IN WEB. 0 LIMITATIONS: 1) NO SQUARE/RECTANGULAR HOLE 2) NOT IN FLANGE 3) NOT NEAR FLANGE (2"MIN. SEPARATION) 4) NO MULTIPLE HOLES IN SAME AREA (MINIMUM SEPARATION: DIA. X 3) 16.1