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Old 10-05-2014, 09:18   #1
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Holding tank and thru-hull protocols.

We just installed a new heads on our oceanis 36CC and revamped the pipework for better operation with an aditional non-return valve, better quality Y-valve and a newer better anti-syphon.

basically we have a simple system where waste can go overboard where permitted or be diverted to the holding tank where not. The holding tank can be pumped out from on deck or again, where legal out at sea, be gravity drained overboard.

All our heads outletcontrol valves, namely the diverter Y-valve (direct overboard or straight to holding tank) and the holding tank outlet thru-hull valve are situated in the shower/toilet area,in closed lockers which have additional hasp & staple locks installed on the doors with combination locks that have number codes only known to me, the Captain, and my wife, the Admiral, there are clear labels installed stating that access to valves/thru-hulls is only available by or with the permission of the Captain. Note that our boat is US documented in my wife's name as the American citizen, me being a 'legal alien' Brit but not allowed to to be the registered owner of a US documented vessel. We are based in Daytona beach Florida and will cruise the east coast USA and Bahamas, including in the ICW.

SO will our new setup be acceptable if we are inspected by the potty police or do we need to additionally cable tie the valves in position when we in protected waters?? We of course want to fully comply when in loca land protected waters but at the same time want to retain flexibility for when cruising offshore, without the need to carry multiple boxes of cable ties and a pair of wire cutters each in our pants pockets and the lockable access seems to me to be a good method

Comments appreciated folks....
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Old 10-05-2014, 09:24   #2
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Re: Holding tank and thru-hull protocols.

For my boat, it is easy enough to just remove the handle w/ the seacock closed.
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Old 10-05-2014, 09:24   #3
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Re: Holding tank and thru-hull protocols.

I think you're really overthinking this. Figure that local LEOs may not be "boat smart" and they would take the rules & regs literally, why not just drill a hole in the Y valve handle(s) and be done with it?
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Old 10-05-2014, 09:32   #4
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Re: Holding tank and thru-hull protocols.

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Originally Posted by Stu Jackson View Post
I think you're really overthinking this. Figure that local LEOs may not be "boat smart" and they would take the rules & regs literally, why not just drill a hole in the Y valve handle(s) and be done with it?
And do what with the hole, thread cable ties through?? This is open to abuse is it not as a devious crew could simply cut, poop, pump and replace tie?? I'm trying to be fully compliant whilst retaining control regardless of who might use the heads and being able to pump and dump when clear out at sea if we wish and are permitted.

But yes I do sometimes overthink stuff.
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Old 10-05-2014, 09:39   #5
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Re: Holding tank and thru-hull protocols.

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Originally Posted by wingless View Post
For my boat, it is easy enough to just remove the handle w/ the seacock closed.
The previous owner of our boat did that and as a result lost the lever holding nut in the bilges somewhere that I cannot find and guess what it is a non standard thread that I have so far failed to find a replacement for ( I believe it may be a metric 9mm 'half nut') When we next haul out we will fit a new thru-hull but in the meantime have borrowed the shower drain valve lever/nut and are using an old lever with a slightly cross threaded nylock nut on that one
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Old 10-05-2014, 09:42   #6
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Re: Holding tank and thru-hull protocols.

I believe the USCG and "clean waters" MSD registration requirement is that the Y-valve is lockable via a padlock while in protected waters.

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Old 10-05-2014, 09:55   #7
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Re: Holding tank and thru-hull protocols.

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Originally Posted by Robin3 View Post
And do what with the hole, thread cable ties through?? This is open to abuse is it not as a devious crew could simply cut, poop, pump and replace tie?? I'm trying to be fully compliant whilst retaining control regardless of who might use the heads and being able to pump and dump when clear out at sea if we wish and are permitted.

But yes I do sometimes overthink stuff.

Sure, that's mpossible. But we've had our boat checked by the CG Auxiliary every year for the past ten years and cable ties have been acceptable.
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Old 10-05-2014, 10:27   #8
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Re: Holding tank and thru-hull protocols.

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Originally Posted by wingless View Post
For my boat, it is easy enough to just remove the handle w/ the seacock closed.
Quote:
Originally Posted by Robin3 View Post
The previous owner of our boat did that and as a result lost the lever holding nut in the bilges somewhere that I cannot find and guess what it is a non standard thread that I have so far failed to find a replacement for ( I believe it may be a metric 9mm 'half nut') When we next haul out we will fit a new thru-hull but in the meantime have borrowed the shower drain valve lever/nut and are using an old lever with a slightly cross threaded nylock nut on that one
When I remove the handle, I replace the hardware onto the seacock, hand tight is fine.

On my boat there is one nearby location that is perfect for the handle, so it will not ever be misplaced.
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Old 10-05-2014, 11:24   #9
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Re: Holding tank and thru-hull protocols.

Earlier this year, I had our boat inspected by the USCG Auxiliary and removing the handle from the 'Y' valve was not sufficient. In addition to 'Y' valve, I had to remove the handle on the macerator thru-hull valve. The inspector's theory was someone could open the thru-hull valve, inadvertently turn on the macerator pump and pump out the holding tank. Crazy.

This actually created a bit of a problem for me. To complete the inspection, I had to remove the handle from the macerator thru-hull valve. In doing so, sea-water started flowing in through the valve. So here's the inspector standing around while I'm trying to remove the handle and figure out why water was pouring into the boat. Turns out the handle wasn't at 90 degrees, so the valve was partially open. The good news is, I checked all the handles and made sure they were properly oriented, so when closed they were actually closed. In a way I'm glad to have discovered the incorrect/offset handle.

For future inspections, I drilled a tiny hole in the end of the handles and looped a bit of seizing wire through each, making a small loop. I can then easily lace a wire-tie through the loops, securing both the discharge and macerator handles together so they can't be opened. A bag of wire-ties and I'm good to go.

This was new this year - I wonder if the USCG is ramping up this requirement or I had a by-the-book inspector?

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Old 10-05-2014, 11:38   #10
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Re: Holding tank and thru-hull protocols.

I would guess that you are OK with that setup. I was once boarded by the USCG at sea with a direct over only head setup. They stated before returning to US waters I should at least put a lock on the head door to be in compliance.
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Old 10-05-2014, 13:55   #11
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Re: Holding tank and thru-hull protocols.

Well at this point in time we have the valves all behind padlocked doors (combination locks with codes only known to us) PLus the tank outlet thru-hull is cable tied shut and the Diverter Y-valve is cable tie locked in the send to holding tank position, so i guess we are currently bullet proof for when we request a free CG survey which is a service they offer locally, but once we get out cruising again proper I would like to have commonsense operational flexibility without needing to carry a pocketful of tools and ties and then needing to get on my hands and knees with my head in a dark locker to do the deed after every visit. I havehad two total hip replacements and a bad stroke so like to keep things simple, that way I don't need to beg the boss lady to do the job for me as that tends to diminish my nookie points
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Old 10-05-2014, 14:15   #12
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Re: Holding tank and thru-hull protocols.

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Originally Posted by Cavalier View Post
I believe the USCG and "clean waters" MSD registration requirement is that the Y-valve is lockable via a padlock while in protected waters.

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I had read the regs but like most things documentational they are open to 'interpretation'. we heard stories of a local Daytona boat returning from a Bahamas cruise and being boarded offshore when only just back inside the limits and before they had found time to replace all the various tiewraps. I think the fines were pretty punitive and may have resulted from an over zealous FDLE office (local marine police IIRC) Anyhow it has served as a warning shot for us to ensure proper compliance of our own new arrangements.
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Old 11-05-2014, 08:22   #13
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Re: Holding tank and thru-hull protocols.

"And do what with the hole, thread cable ties through?? This is open to abuse is it not as a devious crew could simply cut, poop, pump and replace tie?? "

Just keep in mind the intent of the law is not to make it impossible to discharge sewage, but to make it impossible to discharge by accident.

If you are in a no discharge area and you cut a cable tie, open a valve, pump overboard, close the valve and replace the cable tie, you have deliberately broken the law. If you're caught you can't say it was an accident.
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Old 11-05-2014, 09:12   #14
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Re: Holding tank and thru-hull protocols.

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"And do what with the hole, thread cable ties through?? This is open to abuse is it not as a devious crew could simply cut, poop, pump and replace tie?? "

Just keep in mind the intent of the law is not to make it impossible to discharge sewage, but to make it impossible to discharge by accident.

If you are in a no discharge area and you cut a cable tie, open a valve, pump overboard, close the valve and replace the cable tie, you have deliberately broken the law. If you're caught you can't say it was an accident.
That is indeed my understanding also, but then surely my method of having all levers behind securely locked doors achieves the same result, whilst allowing operation in permitted areas if required without the hassle thereafter of rewiring the cat's cradle back up in the depths of a dark locker, since as I said I'm post two hip replacements and a stroke so not agile in tight corners like once upon a time.

I'm going to leave it as is, cable tied and behind securely locked locker doors, until we have the free CG vessel safety check that is offered locally and will decide the final plan after that. my intention is always to comply with the requirements, just not to do so and create other problems.
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Old 11-05-2014, 09:34   #15
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Re: Holding tank and thru-hull protocols.

You are over thinking this a bunch. I've been checked by DNR and CG.

The regulation allows for "by padlock, non-resealable tie, removal of handle or other physical barrier." Releasable ties are the ones where a simple pinch allows removal. The ties do NOT have to be metal. In fact, rigging wire is not as clearly acceptable, though I'm sure it would pass if very well twisted. They do not require locks. The regulation clearly accepts plastic cable ties. Simple.

Obviously there are MANY ways poop can get in the water, no the least of which is a bucket, so the law is not that complicated. Sure, you can use a locked door, but there is NO IMPLICATION that a lock is required. The notion that a crew member would cut the tie, drain, and replace behind the captains back is absurd on the face of it. Why?
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