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Old 08-08-2015, 09:26 PM   #81
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Originally Posted by RickB View Post
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.

Yep, agree, not easy and so far, no luck.


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.

That's the language I don't easily find. I find it's illegal to dump waste, not that it's illegal to dump contents of a holding tank.

???


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.

Enforcement would likely (obviously?) default to dump/no dump, without regard to contents. I get that, don't care, no argument, I'm only intrigued by the language used.

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.

Not trying to read into anything, nor am I trying to justify an action I don't intend to take. Not interested in a debate about whether that action might be harmless or not. Just interested in the process of creating technical documentation (and law, in this case) using clear and unambiguous language.

Comes from a lifetime of creating technical documentation... where we know sometimes the author doesn't say what he/she means... usually caught in the editing process. Especially during the second editing process, when folks are called in who don't already know the material the doc is purporting to describe; they usually identify oddities not apparent to original authors who think they know what they meant, whether they said that or not.

Didn't mean to hijack the original thread intent, just find it comical if a perfectly good bottle of Laphroig or whatever can all of a sudden legally become "waste" simply by nature of spilling it into a new (never before used) "holding tank." Of course that would indeed be "a waste" -- no matter what.



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Old 08-08-2015, 11:06 PM   #82
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I think the issue is...the LEO has no idea that your tank is new and you are only really pumping out $1000 a bottle champagne you dumped down it.

Many enforcement laws are created to be enforceable as the are to actually be correct.

Pump from the tank through a y valve within 3 NM and you are had...champagne or poop....still an infraction.

I love my now totally suitable Raritan Electroscan with salt tank. No trips to the pumpout for the 8 months I am prisoner to my dock because of my job. I hate the mindless no discharge zone regs...but humans are not coherent much of the time so what can I do?
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Old 08-09-2015, 07:38 AM   #83
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Originally Posted by ranger42c View Post

Didn't mean to hijack the original thread intent, just find it comical if a perfectly good bottle of Laphroig or whatever can all of a sudden legally become "waste" simply by nature of spilling it into a new (never before used) "holding tank."
There really isn't much room for interpretation or need for editing, the meaning and intent is crystal clear.

If a boat has a toilet, it has to have an MSD. If the toilet dumps into a holding tank plumbed so that it can be pumped or dumped overboard, the following applies:

"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."

It is hard for anyone, tech writer or enforcement person, to be more clear than that. You will only get in trouble if you try to apply a personal interpretation to the rules or take bad advice from a self-styled "expert" on an internet forum.
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Old 08-09-2015, 07:46 AM   #84
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So now you have declared me a troll. Nice.

And especially surprising since I didnt ask a question. Maybe you should look at post #6. Doesnt look like a question to me at all.

Just out of curiosity, how much has she paid you as a commercial member to gain your loyalty?

It's against the law to dump your waste tank within 3 miles of the coast. Period.
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Old 08-09-2015, 08:18 AM   #85
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Think the operative quote is "You are only as good as your last mistake" and that last one is a doozy that could get someone in (pun intended) very deep shit.

The membership might be better served if some members address the message rather than attack the messenger in defense of an indefensible and potentially damaging statement advising others to violate a federal law.
Rick your right and very good point
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Old 08-09-2015, 08:28 AM   #86
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Rick your right and very good point
Thank you.
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Old 08-09-2015, 08:35 AM   #87
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when one considers how much crap (literally) goes into the water untreated and undiluted by all the creatures that live there. Whales, dolphins, porpoises, seals, sea lions, walruses, manatees, river and sea otters to say nothing of all the fish crapping under the water and the birds crapping into it.
This is one of the biggest loads of excrement in the whole thread and one perpetuated on the interweb far too much. We are talking about an ecosystem here, and all those creatures' effluent has been an integral part of the ocean ecosystem for millions of years. And it is the byproduct of things consumed from that ecosystem. Human waste doesn't belong there, and the less the better. So back to a discussion of how to accomplish that...

(and Peggy is right, BTW ).
An at least cursory flush as part of every pump out goes a long way to reducing and eliminating sludge, and making the job of a very thorough flush that much easier.
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Old 08-09-2015, 10:08 AM   #88
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(and Peggy is right, BTW ).
An at least cursory flush as part of every pump out goes a long way to reducing and eliminating sludge, and making the job of a very thorough flush that much easier.
No one disputed that a flush is beneficial to system operation.

The problem arose when she stated categorically (and repeatedly) that it was a perfectly acceptable practice a to violate a host of federal pollution control laws.
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Old 08-09-2015, 10:26 AM   #89
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"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."

Ah! Hadn't been able to see that wording in your second (Federal) ref above (USCG Systems Engineering Division (CG-ENG-3)) -- apparently a case of age-related blindness. I see it now!

Thanks for your patience and persistence.

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Old 08-09-2015, 10:30 AM   #90
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I think the issue is...the LEO has no idea that your tank is new and you are only really pumping out $1000 a bottle champagne you dumped down it.

Many enforcement laws are created to be enforceable as the are to actually be correct.

I love my now totally suitable Raritan Electroscan with salt tank. No trips to the pumpout for the 8 months I am prisoner to my dock because of my job. I hate the mindless no discharge zone regs...but humans are not coherent much of the time so what can I do?

Yep, realized all along that enforcement issues would drive, no matter what.

Good to hear your system is suitable; been thinking more and more about going that route... partly as a real improvement, and partly because I should eventually do something about my overboard pump anyway.

That pesky cost, though!

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Old 08-09-2015, 11:24 AM   #91
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Originally Posted by ranger42c View Post
Yep, realized all along that enforcement issues would drive, no matter what.

Good to hear your system is suitable; been thinking more and more about going that route... partly as a real improvement, and partly because I should eventually do something about my overboard pump anyway.

That pesky cost, though!

-Chris
Even though I live 1 NM from the ocean....I was getting a bunch of warnings about low amperage (due to marginal salinity).

Raritan said don't worry about it...all is OK.

Generally I am not too anal....but getting a warning for about 1/2 the flushes just rubbed me wrong they would design a system that would do that.

So I broke down and and added a salt tank feeder for when in brackish waters (in them for my trip to Florida every year so it made hand feeding salt a thing of the past).

I have salt water fed toilets so adding the tank was easy...I just tapped into the salt water feed. You are supposed to tap into the fresh water system...but after several conversations with other TFers and friends...decided to use salt water feed to ultimately use less salt and in some places probably none.

Very happy now...but for $2000 total into the system it better work mindlessly and have a decent lifespan.

The pressure to not have to go a pumpout is great...and it is plumbed into the holding tank so when I can discharge after being in a no discharge zone...it is really a poor man's hold and treat .
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Old 08-09-2015, 03:21 PM   #92
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Quote:
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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.
And there in lies the problem of the claim that "It's perfectly legal to dump flushed tanks". You must keep the Y valve secure so that NO DISCHARGES can occur within 3 miles of land.

It has nothing to do with just how clean you think your waste tank is, it has to do with the fact that you can not dump it within 3 miles of land, period. You can however have it pumped out, the keys have free pumpout services for the anchor bouy renters.

Hopefully that portion of the reg is clear enough for everyone.
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Old 08-11-2015, 08:39 AM   #93
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If it is a blocked vent it would be confirmed by opening a toilet to serve as vent.
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Old 08-11-2015, 09:54 AM   #94
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I cleared out the vent on the stern bulkhead yesterday and ran some water down the hose towards the tank. Hopefully that will do something.

I'm realizing now that I've been off the boat for awhile that I have a definite sewage odor when I walk in the door. Especially strong where all the hoses and tank live in the forward bilge. I had a leaking macerator pump that I replaced awhile back and it's all clean in there now, but still has an odor.

Could my hoses be bad already? They are 7 years old.
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Old 08-11-2015, 09:59 AM   #95
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...Could my hoses be bad already? They are 7 years old.
Do you have the white Shield's hose? If that is what you have then I would say yes. It's looks (smells) like it's time to replace.
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Old 08-11-2015, 10:07 AM   #96
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They are thick-looking black hoses. Didn't get the brand name or any numbers off them because was hoping they were OK. 😁

Another poster said maybe I had a u shaped place in the hoses and sewage was resting there?

Is there a way to flush these hoses? Chemicals?
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Old 08-11-2015, 10:09 AM   #97
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The really easy way to surely remain "CLEAN" regarding boating black water is to have a holding tank that has NO overboard discharge capability. A tank that MUST be pumped out for human waste removal... such as we have in our Tolly. This method makes all the shuck and jive about how/what/where to put waste a non-plus. It’s also very easy as compared to cost/installation/maintenance/replacement of pumps, hoses, Y-valves, locks on the Y’s… etc. another item immediately attained is BIG smile on officer’s faces about no chance for in-water discharge.

SF Delta, where we boat, is a fragile eco system. We find it no problem to either pump out at dock while fueling or to pay a mobile pump boat while out and about.

Of course... if we regularly boated 3 + miles off shore we would have on-board pump out capabilities.

Laws are written to best as possible enable society to have acceptable manners of existence. At least that is the prime reason. However laws are not necessarily correct in their ability to thoughtfully/properly cover all aspects of the items they are written for. That said; I am confident that each person has somehow bent the "Letter of the Law" in one way or another regarding items they put into water.

Of all the people contributing to TF’s collective pool of knowledge it is Peggie Hall’s wisdom to which I give one of the highest credits.
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Old 08-11-2015, 12:03 PM   #98
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Could my hoses be bad already? They are 7 years old.
Absolutely. Do the wet rag test and you'll know for sure. If you have no waste water leaks then the smell is almost certainly permeated hoses. We had this problem until we replaced our hose runs with PVC which is impermeable.
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Old 08-11-2015, 12:44 PM   #99
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Hard to pump out black tank

Ok. Damn. Not what I wanted to hear but I don't like the smell so gotta do something.

Will look up wet rag test. Sounds exciting! 😳
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Old 08-11-2015, 07:00 PM   #100
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Just a reminder to ALL to please feel free to post your perspective and opinions, but please refrain from personal attacks and condescension. All offending posts and quotes have been deleted.
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