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Old 21-10-2023, 04:52   #1
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Holding tank refit legality

Refitting a black water system on an older sailboat.

The current configuration is that the head can be pumped directly overboard or to the tank, and the tank can also be pumped overboard with a hand pump (as well as sucked out thru the deck fitting).

Is this type of arrangement still legal? Should I just abandon the hand pump and hoses and just seal off that thru hull?

Also, the Y valve looks newer, but has no way to lock it in the tank position. Is that legal?

Boat will be sailed in Puget Sound, WA.

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Old 21-10-2023, 05:08   #2
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Re: Holding tank refit legality

I haven't heard of any changes here, but.... You do need to find a way to lock that discharge valve shut and keep it shut when you are inside the three mile limit. Be one of the good guys and put an actual padlock on it.

Lots of anchored and docked live-aboard boats, with no access to pump out. Is there something wrong with this picture?
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Old 21-10-2023, 05:18   #3
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Re: Holding tank refit legality

Are you saying the actual THRUHULL fitting must be locked?
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Old 21-10-2023, 05:28   #4
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Re: Holding tank refit legality

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Are you saying the actual THRUHULL fitting must be locked?
No, not necessarily. The system must be “secured” so discharge is prevented. More typically that is done at a Y-valve. Discharge pumps should be restricted so only the Captain has access to actuating them.

Locking the thru-hull is one way, but not the only way, of achieving this. In some systems it might be the only way.
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Old 21-10-2023, 05:36   #5
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Re: Holding tank refit legality

How is it even possible to “secure” a thru hull in the CLOSED position? In the open position, I get it…..zip ties around the handle and hose. But if the handle is 90 degrees to the hose???
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Old 21-10-2023, 05:59   #6
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Re: Holding tank refit legality

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Originally Posted by massnspace View Post
How is it even possible to “secure” a thru hull in the CLOSED position? In the open position, I get it…..zip ties around the handle and hose. But if the handle is 90 degrees to the hose???
Remove the handle
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Old 27-10-2023, 07:21   #7
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Re: Holding tank refit legality

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How is it even possible to “secure” a thru hull in the CLOSED position? In the open position, I get it…..zip ties around the handle and hose. But if the handle is 90 degrees to the hose???
I struggled with that. It's not really possible to be secured in a "secure" fashion, but a zip tie isn't exactly "secure" anyway. This is all about "intent" and "perception" (and I'm not being snarky -- I agree with it).
My solution was to cut up a milk jug, making some oblong 1/2" x 1" pieces. One end had a 1/4" hole that was placed over the stub of the thru-hull bolts, and a nut held it in place. The other end had another 1/4" hole, a zip tie went through that and around the handle. Very "secured" in place -- cannot be opened. Of course, 10 seconds with a knife can open it, another 10 seconds puts another zip tie on. But frankly, since I put it on 5 years ago, it's never been off.
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Old 27-10-2023, 07:59   #8
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Re: Holding tank refit legality

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I struggled with that. It's not really possible to be secured in a "secure" fashion, but a zip tie isn't exactly "secure" anyway. .
Astonishing how complicated some make of a very simple solution.
No zip tie, no milk jug, no lock, …..

Just remove the handle.
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Old 27-10-2023, 08:39   #9
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Re: Holding tank refit legality

Consider removing all that plumbing and installing a composter…no discharge….no pumpout…no stinky hoses/tank….just a 5gal bucket with a seat on it….$200 to $1000….so simple it is a no brainer. We refitted our 83 31 Dufour when we bought her in Main 5 years ago and brought her to Ontario… After sailing NE coastal to Main. And Chesy on previous boats w/ tanks and pumpout….would never go back!

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Old 27-10-2023, 07:26   #10
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Re: Holding tank refit legality

Quote:
Originally Posted by massnspace View Post
How is it even possible to “secure” a thru hull in the CLOSED position? In the open position, I get it…..zip ties around the handle and hose. But if the handle is 90 degrees to the hose???
If the door to the head is locked, that satisfies the legal requirement. Of course, that means no pooping within 3 miles of shore.
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Old 21-10-2023, 05:47   #11
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Re: Holding tank refit legality

Lots of boats are still nuilt that way. I have passed the USCG inspections with the Y valve handle removed and in the closed position. You still need a way to "secure" the tanks thru hull in the closed position as note above zip ties work.
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Old 21-10-2023, 05:59   #12
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Re: Holding tank refit legality

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How is it even possible to “secure” a thru hull in the CLOSED position? In the open position, I get it…..zip ties around the handle and hose. But if the handle is 90 degrees to the hose???
Yeah, this is often a problem. In the past when I had a holding tank system the through-hull was close enough to a bulkhead that I could put an eyebolt through the bulkhead that a padlock could go through and around the handle on the seacock. On Lake Champlain we had to remove the actual hose that connected to the through-hull, and in some cases that might be the easiest solution, depending on how hard it is to remove and put it back on. I have read that someplaces allow you to just ziptie the handle in the closed position. I once thought of creating a short length of SS cable to put around the seacock and hose with a padlock. A big bicycle U-Bolt lock might work also. I would ask around the local boating community there to see what is required. The only place I have ever had my head inspected was in Rhode Island, where it is mandatory and you need to get a stupid sticker to put on your boat to prove it.
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Old 21-10-2023, 05:57   #13
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Re: Holding tank refit legality

I'm on the Great Lakes which is all No Discharge so very few boats here are equipped for overboard discharge. My prior boat came from Long Island Sound so it did have a discharge through hull, and it was old enough (1969) that it didn't originally have a holding tank. When it came here they took the hose barb off the seacock and replaced it with a plug. No need for a lock as the seacock wasn't connected to anything. So if you're going to be in an NDZ long enough this is a good option.
By the regulation, it doesn't have to be locked, just disabled in some way. Simply removing the handle is good enough. If the plumbing is still connected none of these things really prevent you from discharging, they just make it a little harder. Even a lock isn't permanent unless you throw away the key.
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Old 27-10-2023, 07:29   #14
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Re: Holding tank refit legality

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I'm on the Great Lakes which is all No Discharge so very few boats here are equipped for overboard discharge.
No Discharge Zone is activist hyperbole for the nearly inconsequential impact of an NDZ. NDZ is more properly called "No Lectrasan Zone." An NDZ has zero impact on 95% (99%?) of boats. The vast majority of boats, ones with holding tanks, have been "No Discharge" (except outside the limits) for decades. An NDZ prohibits operation of an otherwise legal Lectrasan. It sounds impressive, but has very little environmental impact -- but has a HUGE financial impact on the very small number of affected boats.
Note, I'm not sure how NDZ and such apply to the Great Lakes. For the rest of the country, an NDZ only impacts water up to the 3 mile limit, beyond that there are no restrictions. I'm not sure how the Great Lakes implement those regulations, or even how the Clean Water Act (the origination of holding tanks and NDZs) addressed the 3-mile limit in the Lakes.
My current boat, like most, has a holding tank. As I sail in and out of NDZs here on the East Coast, nothing changes. In an NDZ, I can't discharge. when I leave an NDZ -- I can't discharge.
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Old 27-10-2023, 11:31   #15
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Re: Holding tank refit legality

Note, I'm not sure how NDZ and such apply to the Great Lakes.

The entire Great Lakes became NDZ under a treaty with Canada in the 1960s, long before the CWA mandated marine sanitation regulations.

40 CFR 140.3 turned all non-navigable inland waters and intrastate lakes into NDZ as a result of the CWA in 1978

The EPA publishes a list of NDZs--which they keep updated--here
EPA NDZ list

Waters in which the discharge of TREATED waste is legal (and there are more of them US coastal waters on both coasts and the Gulf than you think) are NOT NDZ, they only make it illegal to discharge raw waste, which is illegal in all US waters both coastal and inland. You must be in open sea at least 3 miles from the nearest point on the entire US coast line or offshore island to discharge (defined as includes, but is not limited to, any spilling, leaking, pumping, pouring, emitting, emptying, or dumping) a tank or flush a toilet directly overboard.


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