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Old 14-05-2009, 19:16   #16
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Just found this terrific article.... just in time for some refit!
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Old 30-06-2015, 08:54   #17
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Re: Nigel Caulder on Hoses

I know this is an ancient thread, but I am researching section 159.83 which says requires a "a means of indicating when the device is more than three-quarters full" because it came up in a survey report on a boat I am buying.

I appreciate the Chalder is a god on boat systems (I owe him much) and I'm someone you've never heard of, but I don't think Chalder is correct on this one.

+++

Take a look at this page:

http://www.uscg.mil/hq/cg5/nvic/pdf/2009/NVIC_1-09.pdf

It discusses the various protocols and rules for waste systems in great detail.



The relevant section, 159.83 ( which is the same as 33 CFR 159.83) is in this part:

"d. Performance Testing Program
The performance testing program composes three discrete protocols, one for each type of sewage system having its own operational requirements and related discharge criteria. In addition, each of these three protocols comprises four phases that start with an evaluation of the manufacturer’s documentation and is followed by an inspection of the equipment design and construction, environmental (i.e., mechanical) testing, and finally analytical testing of the effluent.

(1)Sewage Treatment Plant Protocol. Aqualified facility evaluates, inspects, and tests the manufacturer’s
sewage treatment plant and effluent discharged from that system for compliance with MARPOL Annex IV using the protocol in paragraphs a through d below.

b)Design & construction inspection. The laboratory performs an independent inspection on the production model for which type approval is requested as well as on the material from which the system is constructed using each of the following standards:
... 159.83 ..."

+++

Paragraph 3 deals with type III MSDs (i.e. holding tank):

"(3)Sewage Holding Tank Protocol. A recognized facility, as defined in reference (e), evaluates, inspects, and tests the manufacturer’s sewage holding tank for compliance with MARPOL Annex IV using the procedures for a USCG Type III certified device in 33 CFR Part 159"


Thus, the relevant section (159.83) seems to apply only to what they call a "Sewage Treatment Plan" (or MSD type I) and not a type II or III device.
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Old 30-06-2015, 10:16   #18
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Re: Nigel Caulder on Hoses

Nigel Calder states that the measuring device is to prevent overfilling of holding tanks. Seems right enough to me.
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Old 30-06-2015, 10:42   #19
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Re: Nigel Caulder on Hoses

Quote:
Originally Posted by FSMike View Post
Nigel Calder states that the measuring device is to prevent overfilling of holding tanks. Seems right enough to me.
No problem with that.

What I question is the assertion that the rule requires it for small pleasure craft.

According to the USCG Navigation Circular I linked to, the requirement of this regulation applies to Type I (i.e. sewage treatment plants) on larger vessels (e.g. passenger ships) and not to Type III (holding tank) systems on small private pleasure craft.
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Old 30-06-2015, 13:14   #20
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Re: Nigel Caulder on Hoses

Quote:
Originally Posted by Iriemon View Post
I know this is an ancient thread, but I am researching section 159.83 which says requires a "a means of indicating when the device is more than three-quarters full" because it came up in a survey report on a boat I am buying.

I appreciate the Chalder is a god on boat systems (I owe him much) and I'm someone you've never heard of, but I don't think Chalder is correct on this one.

+++

Take a look at this page:

http://www.uscg.mil/hq/cg5/nvic/pdf/2009/NVIC_1-09.pdf

It discusses the various protocols and rules for waste systems in great detail.



The relevant section, 159.83 ( which is the same as 33 CFR 159.83) is in this part:

"d. Performance Testing Program
The performance testing program composes three discrete protocols, one for each type of sewage system having its own operational requirements and related discharge criteria. In addition, each of these three protocols comprises four phases that start with an evaluation of the manufacturer’s documentation and is followed by an inspection of the equipment design and construction, environmental (i.e., mechanical) testing, and finally analytical testing of the effluent.

(1)Sewage Treatment Plant Protocol. Aqualified facility evaluates, inspects, and tests the manufacturer’s
sewage treatment plant and effluent discharged from that system for compliance with MARPOL Annex IV using the protocol in paragraphs a through d below.

b)Design & construction inspection. The laboratory performs an independent inspection on the production model for which type approval is requested as well as on the material from which the system is constructed using each of the following standards:
... 159.83 ..."

+++

Paragraph 3 deals with type III MSDs (i.e. holding tank):

"(3)Sewage Holding Tank Protocol. A recognized facility, as defined in reference (e), evaluates, inspects, and tests the manufacturer’s sewage holding tank for compliance with MARPOL Annex IV using the procedures for a USCG Type III certified device in 33 CFR Part 159"


Thus, the relevant section (159.83) seems to apply only to what they call a "Sewage Treatment Plan" (or MSD type I) and not a type II or III device.
33 CFR 159.83 is a subsection of 33 CFR Part 159, so it applies.

I wonder if a translucent tank fits the definition of "indicating."

And just to clear some things up, a Type 1 MSD is a device that treats raw sewage by maceration and addition of biocides to reduce bacteria levels below a certain threshold. The result can then be discharged in US coastal waters, except in NDZs. A Type 1 device is intended for vessels less than 65 feet.

A Type 2 device is basically the same thing, but for vessels larger than 65 feet. And a lower bacteria threshold.

A Type 3 device is a holding tank, intended to hold raw sewage until you can get far enough offshore to legally discharge, or to a pump out facility.

I'm going with Calder on this one.
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