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21-10-2023, 04:52
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#1
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Registered User
Join Date: May 2015
Location: Seattle
Boat: Custom 28' Power Catamaran
Posts: 309
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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.
David
Seattle
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21-10-2023, 05:08
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#2
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Moderator
Join Date: Feb 2012
Location: Carrabelle, Florida
Boat: Fiberglas shattering 44' steel trawler
Posts: 6,084
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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?
__________________
Never let anything mechanical know that you are in a hurry.
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21-10-2023, 05:18
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#3
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Registered User
Join Date: May 2015
Location: Seattle
Boat: Custom 28' Power Catamaran
Posts: 309
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Re: Holding tank refit legality
Are you saying the actual THRUHULL fitting must be locked?
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21-10-2023, 05:28
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#4
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Registered User
Join Date: Jan 2023
Posts: 1,561
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Re: Holding tank refit legality
Quote:
Originally Posted by massnspace
Are you saying the actual THRUHULL fitting must be locked?
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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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21-10-2023, 05:36
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#5
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Registered User
Join Date: May 2015
Location: Seattle
Boat: Custom 28' Power Catamaran
Posts: 309
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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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21-10-2023, 05:47
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#6
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Registered User
Join Date: Dec 2007
Location: Hawaii
Boat: Tartan T4400
Posts: 382
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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.
__________________
Aloha
Mike
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21-10-2023, 05:57
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#7
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Registered User
Join Date: May 2015
Location: Muskegon, Mi
Boat: Columbia 36
Posts: 1,213
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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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21-10-2023, 05:58
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#8
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Registered User
Join Date: Jun 2019
Location: Rochester, NY
Boat: Chris Craft 381 Catalina
Posts: 6,348
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Re: Holding tank refit legality
For thru hulls and Y valves, either ziptie the handle so it can't be opened or remove the handle with the valve in the closed or tank position and you should be good to go.
Basically, if it takes multiple deliberate actions to cause a discharge, then you're in good shape, as you're clearly showing intent to comply with the rules.
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21-10-2023, 05:59
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#9
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Registered User
Join Date: Jul 2006
Location: Massachusetts
Boat: Finnsailer 38
Posts: 5,389
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Re: Holding tank refit legality
Quote:
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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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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21-10-2023, 05:59
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#10
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Registered User
Join Date: Oct 2007
Location: Lakewood Ranch, FLORIDA
Boat: Alden 50, Sarasota, Florida
Posts: 3,502
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Re: Holding tank refit legality
Quote:
Originally Posted by massnspace
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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Remove the handle
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21-10-2023, 07:28
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#11
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Marine Service Provider
Join Date: Feb 2011
Posts: 3,033
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Re: Holding tank refit legality
You'll find everything you need to know about "securing" a system" here 33 CFR 159.7 "Requirements for Vessel Operators." Fwiw, Puget Sound is now an NDZ (no discharge zone) that extends all the way across the Strait and includes the San Juans...so your system will have to remain "secured" until/unless you sail into open seas at least 3 miles from the nearest island or point on the whole US coastline.
You can ignore references to "40 CFR" in the above 'Requirements..."....it only pertains to inland waters.
--Peggie
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21-10-2023, 07:58
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#12
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Registered User
Join Date: Dec 2020
Location: Pacific Northwest
Boat: Pacific Seacraft 31
Posts: 29
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Re: Holding tank refit legality
I was boarded by the Coast Guard this year for a safety check in the Puget Sound. When it came to the discharge check, they were satisfied with only the Y valve being zip tied.
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21-10-2023, 11:01
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#13
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Registered User
Join Date: Apr 2016
Location: Schuylerville, NY
Boat: Wellcraft portofino 43’
Posts: 433
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Re: Holding tank refit legality
Having as padlock is meaningless. Is the key on a nail next to the lock, in the tool box, or on the captain's keychain? The padlock, if a key is available, does not disable the valve. It's doubtful that hiding the key would convince the marine patrol that the valve is disabled.
A few years ago I asked law enforcement to seal it. The officer ran a seal wire (the type used for evidence) through the valve holes, attached a tag indicating the date sealed, then crimped a lead seal onto it. There is no way to move the valve to allow overboard pumping without breaking the seal. A marine patrol of a different state checked the boat a year or two after the seal was applied and it was accepted. You may have to shop around to find a law enforcement agency to do this as most probably do not offer this service.
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21-10-2023, 11:10
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#14
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Registered User
Join Date: Mar 2014
Location: Maryland USA
Boat: Beneteau Oceanis 37
Posts: 83
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Re: Holding tank refit legality
Quote:
Originally Posted by David Mathis
Having as padlock is meaningless. Is the key on a nail next to the lock, in the tool box, or on the captain's keychain? The padlock, if a key is available, does not disable the valve. It's doubtful that hiding the key would convince the marine patrol that the valve is disabled.
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I don’t think it’s fair to call a padlock meaningless if the CFR specifically allows padlocking as an acceptable method. Go the extra step if you’d like or if you’re worried an inspector doesn’t know the law, but that is above and beyond the legal requirement.
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21-10-2023, 12:59
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#15
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Registered User
Join Date: Feb 2008
Location: North Charleston, SC
Boat: Camano Troll
Posts: 5,176
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Re: Holding tank refit legality
All you have to do is make it so nobody can accidentally pump raw sewage overboard. This can be done with wire ties or a padlock on valve handles or by removing valve handles after they have been set in the correct position.
I don't know about flushing a head directly overboard, personally< would rather see the sewage (poop and paper) go into the holding tank where it will be chopped up a bit.
Personally, on my boat there are no valves, everything goes to the holding tank where it can either be sucked out by a pumpout station or pumped overboard by the onboard macerator pump. To make this "legal", I replaced the switch with a key switch and I don't keep the key in the switch.
__________________
Ron
HIGH COTTON
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