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Old 08-07-2015, 08:34 AM   #61
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Originally Posted by ranger42c View Post
In these refs:


Marine Sanitation Devices | Vessel Water Discharge | US EPA


USCG Systems Engineering Division (CG-ENG-3)


I don't see a prohibition about dumping MSD III contents, just "treated or untreated waste" or "waste derived from sewage."


I don't see wording that equates water in a holding tank to sewage (treated or untreated) or waste derived from sewage.


??


-Chris
From the first link...

Typically a holding tank where sewage is stored until it can be disposed of shore-side or at sea (beyond three miles from shore)

and

No performance standard, but pursuant to Coast Guard regulations, a Type III MSD must "be designed to prevent the overboard discharge of treated or untreated sewage or any waste derived from sewage". 33 CFR 159.53(c).


diluted waste is still waste.....
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Old 08-07-2015, 11:02 AM   #62
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IMHO, laws are normally very carefully worded to prevent individual interpretation, in other words, there should be no 'grey' areas. In the case of the 3 mile law, it's pretty clear.

Where we all differ, is on levels of conservation we practice, environmental footprints we leave and in the strength of our convictions.

There is no better platform to air these beliefs, or defend our convictions, than discussion Forums like this. However, name calling and insinuations really don't help prove a point and so, in keeping with the thread theme, let's cut the crap and keep it clean
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Old 08-07-2015, 11:10 AM   #63
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Here is some of the "language" the USCG uses that was put out by the State of California......

Federal Marine Sanitation Device Regulations

2. Should I go flowthrough or no-discharge?
There are two varieties of marine sanitation equipment. One variety treats the waste and then discharges it into the water (Type I or Type II). The second retains the waste onboard or treats it in a manner which does not result in any discharge into the water (Type III). This includes holding tanks, recirculators and incinerators. ...

Remember that it is illegal to pump the contents of a holding tank overboard in U.S. waters.

diluted waste is still waste.....


Potentially useful ref, thanks. Do you think sentence diagramming and context suggests "any discharge" in the first means "waste discharge" ?

The part that starts "Remember that it is illegal..." suggests there is a ref that specifically says "it is illegal to pump the contents [any contents, my interjection] of a holding tank overboard." Have you seen a legal ref that really says that? IOW, not just an admonition to "remember" something that must be printed elsewhere?

I'd have thought a cleaned tank -- not with diluted waste, but actually cleaned, with something like chlorine or whatever -- contains no waste.

FWIW, I wasn't particularly interested in the debate about whether one can/not/should/not flush a "rinsed" tank... was only questioning about whether contents (any contents) of a holding tank automatically become waste simply because of where they (the contents) are.

And I'm really only paying attention because I've got an in-op overboard macerator, been that way for a year or two, need to come up with a fix, and I'm debating between a simple pump replacement (cheap) or installation of a Type I (not so cheap, and would have acquisition, installation, management, and winterization costs). Given that I'm usually inshore, the simple macerator adds little value... but the cost of a Type I might be offset by convenience while on board (?) and the eventual savings in pump-out costs. (Our nearest pump-out facility is not State-subsidized... so it's adding up.)

-Chris
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Old 08-07-2015, 11:22 AM   #64
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Potentially useful ref, thanks. Do you think sentence diagramming and context suggests "any discharge" in the first means "waste discharge" ?

The part that starts "Remember that it is illegal..." suggests there is a ref that specifically says "it is illegal to pump the contents [any contents, my interjection] of a holding tank overboard." Have you seen a legal ref that really says that? IOW, not just an admonition to "remember" something that must be printed elsewhere?

I'd have thought a cleaned tank -- not with diluted waste, but actually cleaned, with something like chlorine or whatever -- contains no waste.

FWIW, I wasn't particularly interested in the debate about whether one can/not/should/not flush a "rinsed" tank... was only questioning about whether contents (any contents) of a holding tank automatically become waste simply because of where they (the contents) are.

And I'm really only paying attention because I've got an in-op overboard macerator, been that way for a year or two, need to come up with a fix, and I'm debating between a simple pump replacement (cheap) or installation of a Type I (not so cheap, and would have acquisition, installation, management, and winterization costs). Given that I'm usually inshore, the simple macerator adds little value... but the cost of a Type I might be offset by convenience while on board (?) and the eventual savings in pump-out costs. (Our nearest pump-out facility is not State-subsidized... so it's adding up.)

-Chris
I think it is all flyshi* more than anything.

As has been pointed out...it is all about personal tolerance of what they put into the environment.

The letter of the law in my former CG experience says flushing is wrong and subject to enforcement....the reality is you can regularly dump a full untreated tank and get away with it as many boaters do regularly.

I went with a Electroscan by Raritan for convenience...dang $2000 by the time I was done with it and I'm pissed at all the "no discharge" zones when I know it is a ridiculous set of regulations that cant be enforced and the pleasure boater is the target of zealots without reason.

I would rather have someone flush a near empty holding tank once and awhile rather than the many who pump their gray water over continuously full of gosh knows what. Then their bilge pumps only add to the problem.

So....what to do...only your moral guide works here...not the claims of zealots, practices of "experts", the reason of normal boaters or even the letter of the law. All can be followed or ignored and gotten away with.

It is an individual dilemma...I chose my path...I think of it as a happy medium.
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Old 08-07-2015, 11:27 AM   #65
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Back to what started the post. If the vent is clogged, use a wet vac at either end to remove the object.
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Old 08-07-2015, 11:42 AM   #66
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"It is illegal to discharge at any time from Type III Marine Sanitation Devices."

Sewage | Clean Green Boating | Washington State Department of Ecology


"Y valve. Type III MSDs having a through hull Y valve must only be opened when the vessel is offshore, beyond the limit of U.S. territorial waters. At all other times, the valve must be positively secured in a way that presents a physical barrier to valve use and prevents all discharges."

Note the use of the words "all discharges." A discharge is defined by the CG as:

"
... any emission (other than natural seepage), intentional or unintentional, and includes, but is not limited to spilling, leaking, pumping, pouring, emitting, or dumping."

USCG Systems Engineering Division (CG-ENG-3)

Regardless of personal feelings and practices, the fact remains that a so-called "expert" claimed in post #42 that it is legal to rinse and dump a holding tank. That is what gave this thread traction ... and it illustrates what a former moderator mentioned not long ago ... that 2 + 2 doesn't always add up to 4 on this forum. Caveat emptor if you are going to act on advice posted on an enthusiast's forum.
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Old 08-07-2015, 01:45 PM   #67
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Originally Posted by ranger42c View Post
How would that be an improvement? And what macerator does he have and why is it a POS?

-Chris
Because the grinder style of macerator pumps, which it sounds like he may have, are POS IMO. While a good diaphragm pump is much less likely to clog, can run dry almost forever and is simple to service.
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Old 08-08-2015, 08:27 AM   #68
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With a diaphragm pump the usual problem is not running dry or clogging.

It is a tiny bit of waste that was not flushed from the pump after use that sticks to the inlet flapper valve.

This causes no suction , so a repair is required.

That is why I suggest the pump be gravity fed , if full it will pump from the start.

No real service problem if the hose from the tank discharge is long enough to allow the gravity pump to be lifted above the waste tank for repairs.
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Old 08-08-2015, 03:48 PM   #69
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Because the grinder style of macerator pumps, which it sounds like he may have, are POS IMO. While a good diaphragm pump is much less likely to clog, can run dry almost forever and is simple to service.

Thanks; I think I don't know enough about how a diaphragm pump works (compared to an impeller) to appreciate the differences. I'll research. Can you mention an example diaphragm pump?

-Chris
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Old 08-08-2015, 03:50 PM   #70
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We have a Dometic Series T diaphragm waste pump. Works like a charm, and is very quiet.
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Old 08-08-2015, 03:53 PM   #71
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Quote:
Originally Posted by RickB View Post
"It is illegal to discharge at any time from Type III Marine Sanitation Devices."

Sewage | Clean Green Boating | Washington State Department of Ecology


"Y valve. Type III MSDs having a through hull Y valve must only be opened when the vessel is offshore, beyond the limit of U.S. territorial waters. At all other times, the valve must be positively secured in a way that presents a physical barrier to valve use and prevents all discharges."

Note the use of the words "all discharges." A discharge is defined by the CG as:

"
... any emission (other than natural seepage), intentional or unintentional, and includes, but is not limited to spilling, leaking, pumping, pouring, emitting, or dumping."

USCG Systems Engineering Division (CG-ENG-3)

Thanks for refs; do you know if there's somewhere in USCG language that says the same thing ("prevents all discharges") as the Washington State language?

I'm intrigued to hear the concept that clean water fed into a clean/never used holding tank (imagine as in a new boat) can maybe -- by definition -- become "treated or untreated waste" simply because of where it is.

-Chris
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Old 08-08-2015, 03:55 PM   #72
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Originally Posted by psneeld View Post
I think it is all flyshi* more than anything.

I went with a Electroscan by Raritan for convenience...dang $2000 by the time I was done with it and I'm pissed at all the "no discharge" zones when I know it is a ridiculous set of regulations that cant be enforced and the pleasure boater is the target of zealots without reason.



Aside from the many NDZs in your various stomping grounds... how pleased (or not) are you with the treatment system? Does it really provide convenience (where usable)? Work OK? Require management? etc.?

-Chris
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Old 08-08-2015, 04:19 PM   #73
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In 15 years of use between 2 boats, never a failure and always worked. The grinder type macerater pumps, as Capt Biill mentioned, are pos. We had a guest on board one time with those little rubber bands from her braces. They messed with my diagnostic skills and 2 pumps for a month. The Dometic. pump will swallow marbles (although not recommended).

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We have a Dometic Series T diaphragm waste pump. Works like a charm, and is very quiet.
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Old 08-08-2015, 04:43 PM   #74
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Hard to pump out black tank

Maybe I will get one of those Dometic pumps when my current one takes a sh&t.
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Old 08-08-2015, 05:33 PM   #75
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Thanks for refs; do you know if there's somewhere in USCG language that says the same thing ("prevents all discharges") as the Washington State language?
The CFRs are published and accessible to the public ... it just takes time to search and read them. Not to say that is easy or particularly rewarding.

Quote:
I'm intrigued to hear the concept that clean water fed into a clean/never used holding tank (imagine as in a new boat) can maybe -- by definition -- become "treated or untreated waste" simply because of where it is.
The regs say that a type III MSD is a system that receives waste (sewage) and holds it for disposal at a shore pumpout or may be legally pumped overboard outside the 3 mile line. The regs do not address the past, present, or future contents or the quality of those contents, they only state that it is illegal to discharge or dump a holding tank except outside 3 miles or at a shore pumpout. The regs state that it is illegal to open the overboard valves except beyond 3 miles. That is the bottom line and really all that matters.

Like I said before, the regs do not say that a LEO, EPA inspector, or CG boarding officer must determine what you are pumping or dumping to complete the offense or that the discharge must be a certain color or odor or be potable or poisonous.

Trying to read too much into the regs is a pointless exercise as is trying to find a rhetorical loophole for doing what may indeed be harmless but still illegal.
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Old 08-08-2015, 05:46 PM   #76
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With a diaphragm pump the usual problem is not running dry or clogging.

It is a tiny bit of waste that was not flushed from the pump after use that sticks to the inlet flapper valve.

This causes no suction , so a repair is required.

That is why I suggest the pump be gravity fed , if full it will pump from the start.

No real service problem if the hose from the tank discharge is long enough to allow the gravity pump to be lifted above the waste tank for repairs.
In the real world the likelyhood of that really happening is very, very small. In fact in my 30+ years of dealing with diaphragm pumps I can't recall it ever happening.

And would take a piece of waste much larger than " tiny" to cause the effect you describe. As a diaphragm pump can still develop some suction even with a slightly open duck valve or flapper valve. So "tiny" pieces of waste that get stuck in the valve end up getting washed away.
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Old 08-08-2015, 05:46 PM   #77
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We have a Dometic Series T diaphragm waste pump. Works like a charm, and is very quiet.
What he said.
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Old 08-08-2015, 07:08 PM   #78
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Hard to pump out black tank

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What he said.

Don't know much about these things other then they're pretty darn simple and I have a spare one in the box under the bed in the boat in case all else fails. Our grey water pump is also a Series T.
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Old 08-08-2015, 08:47 PM   #79
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The Whale Gulper is said to be another good diaphragm pump for shower sumps, waste pumping, etc.
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Old 08-08-2015, 09:19 PM   #80
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The Whale Gulper is said to be another good diaphragm pump for shower sumps, waste pumping, etc.

We have one for the bilge and it's a tank, I once left it on for a a day and it was fine, its role is plainly for nuisance water in the bilge. For serious pumping we have a 180GPM Pump.
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