Gray water holding tanks

[chrisray]

The USCG marine inspector in Seattle tells me in order to get my COI renewed after being in drydock for 4 months getting hull repairs, etc.,on my 1986 Seatrek 94’ commercial charter boat, I now need to install gray water holding tanks. Plus drawings on placement. There are 2 showers and sinks in the 3 heads, a sink in the galley and a bar sink. One shower and sink on top deck, galley sink and bar sink on main deck. Anyone know how I’m supposed to do this or where I can get info on the procedure? The Department of Ecology has given small commercial passenger vessels till May 10, 2023 to retrofit. But this inspector insists we need these tanks installed BEFORE he’ll give us our COI. HELP PLEASE. COVID has kicked our rear ends and we need to get back to work.

[ranger58sb]

Just making some guesses, to get ideas flowing...

Can you identify a likely space for a gray water holding tank? And a way to get it there?

(Ronco Plastics makes great tanks; you pick size, shape -- from several bazillion options -- and then you customize where inlet, outlet, and vent fittings go.)

I'd suppose your current showers and sinks are all plumbed to drain overboard? You could just re-route those hoses to the new gray water tank?

You'd need a way to empty the gray water tank. New deck fitting for that?

(What body of water -- and associated law -- forces you to have gray water tanks? How does Seattle deal with gray water? Handle that at pump-out stations, too? Extra cost?)

-Chris

[tkeithlu]

Welcome to the forum, Chris Ray.

Wow! Regional differences. In Florida, all our gray water goes overboard, immediately. Of course, we are recreational, but I have not heard of such restrictions.

Ranger42c has the best approach; find a location, install, re-route. You might need to route to a sump, sit a bilge pump in it, and then pump to the holding tank. We use a sump for the lower deck shower and basin - it's just a small aluminum box. The only problem is keeping up with my wife's long hair getting caught - it needs occasional cleaning just like a bathroom basin drain does.

The only other route I can think of is routing into the blackwater tank, and then pumping out more often. I don't know whether that would satisfy your inspector.

[sailormed]

".....on my 1986 Seatrek 94’ commercial charter boat, "
I think the clue is in the word commercial. Not a pleasure craft.

[GordMay]

Greetings and welcome aboard the CF, Chris.

[Dsanduril]

Welcome Chris. Unfortunately, you have stepped into a minefield. You might politely ask the inspector to show you the regulations. In doing so the following information might be helpful:

USCG Graywater Installation Requirements

But, this is what the USCG currently says about graywater:

Graywater.
Graywater includes drainage from dishwater, shower, laundry, bath, and washbasin drains but not from toilets, urinals, hospital spaces, and cargo spaces. Graywater is not sewage and therefore may be discharged overboard without passage through an MSD or a holding tank, except where otherwise prohibited. For more information see the graywater white paper. source

The EPA, under VIDA has published the proposed rule, but it is not yet final:

Pursuant to VIDA, the following interim requirements apply until EPA publishes future standards and the USCG publishes corresponding implementing regulations under VIDA (anticipated in 2022):

For large, non-fishing commercial vessels: The existing vessel discharge requirements established through the EPA 2013 Vessel General Permit (VGP) and the USCG ballast water regulations, and any applicable state and local government requirements.

For small vessels and fishing vessels of any size: The existing ballast water discharge requirements established through the EPA 2013 VGP and the USCG ballast water regulations, and any applicable state and local government requirements. source

Bottom line, under VIDA you should still be able, at the federal level, to discharge graywater as before. I don’t know anything about the local level in WA.

PS, you are a “large vessel”, the dividing point is 79 feet.

[BillKny]

Originally Posted by chrisray

The USCG marine inspector in Seattle tells me in order to get my COI renewed after being in drydock for 4 months getting hull repairs, etc.,on my 1986 Seatrek 94’ commercial charter boat, I now need to install gray water holding tanks. Plus drawings on placement. There are 2 showers and sinks in the 3 heads, a sink in the galley and a bar sink. One shower and sink on top deck, galley sink and bar sink on main deck. Anyone know how I’m supposed to do this or where I can get info on the procedure? The Department of Ecology has given small commercial passenger vessels till May 10, 2023 to retrofit. But this inspector insists we need these tanks installed BEFORE he’ll give us our COI. HELP PLEASE. COVID has kicked our rear ends and we need to get back to work.

This is SERIOUSLY the wrong place to get good advice about compliance with commercial vessel regulations, especially for inspected vessels. You'll get lots of bad advice. You need to talk to your local shipyard about doing this.

On an inspected vessel this level of modification is NOT a simple DIY job. It will almost certainly involve structural and stability calculations. If you don't understand that, you probably shouldn't be running an inspected vessel.

MAYBE you can appeal the inspector's rulings, but I be surprised. I have seen people try even when there were clearly unreasonable demands, but it is usually faster and cheaper in the long run to just suck it up, salute, and say "Yes, Sir!"

[guyrj33]

I suggest consulting both a maritime lawyer and an engineer.

[Dsanduril]

Digging into the WA requirements specifically, the Puget Sound NDZ established in 2018 does not affect graywater. The 5-year implementation period only affects sewage discharge.

​When did the Puget Sound NDZ take affect?
The NDZ for Puget Sound and certain adjoining waters came into effect on May 10, 2018, with the adoption of Chapter 173-228 WAC in April 2018. However, certain commercial vessels have a five-year delay before the rule begins. There is no change for graywater discharges....

What about graywater?
The NDZ does not affect graywater discharges. The Clean Green Boating website has information on best management practices and requirements for graywater, as well as other potential discharges such as fueling, bilge care, and hull cleaning.

source: WA Dept. of Ecology

At this point I'd very politely ask for a reference to the regulations requiring graywater storage so that I could work with the shipyard to design the system/implementation. Certainly the inspector should have that since s/he has to inspect against it. Once you know where s/he is coming from you can actually have a discussion.

[valhalla360]

Originally Posted by Dsanduril

At this point I'd very politely ask for a reference to the regulations requiring graywater storage so that I could work with the shipyard to design the system/implementation. Certainly the inspector should have that since s/he has to inspect against it. Once you know where s/he is coming from you can actually have a discussion.

Exactly, if the inspector wants to enforce a rule, he needs to provide the rule.

For all we know, he may be misapplying the rule.

If you respond blindly, very good chance, he comes back and claims you didn't address his concern correctly.

[Mike Banks]

You can probably get away with fitting more than one tank. On my vessel I used the shower and wash basin water (but not the galley waste) as flush water in the heads--whence it went to the black water holding tankage. The grey water tanks were pre-charged with the same sterilant used in the blackwater holding tanks. This was done via the shower sump, or by pouring concentrate into the tank itself. Obviously there is more shower water than is needed for the flushing of a marine electric head, but guests will use a lot more water than a sailor mindful of over-use.

Once the flush-tank is full, it overflows to the main greywater tank, which I also charged with holding tank sterilant. You just do not need to use as much as you would in the blackwater tank, but if you do NOT use it, or some other bactericide, the greywater will stink making it unusable. If you can avoid using sea-water in your heads flush, you will solve a great many problems of mineral build-up.

Commercial vessels operate under different rules--so you should check that you are able to re-use the grey water. Being able to do so means less greywater tankage will be required.