Hard to pump out black tank

ranger42c said:

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

Click to expand...

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.....

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

psneeld said:

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.....

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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

ranger42c said:

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

Click to expand...

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.

Back to what started the post. If the vent is clogged, use a wet vac at either end to remove the object.

"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.

ranger42c said:

How would that be an improvement? And what macerator does he have and why is it a POS?

-Chris

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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.

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.

Capt.Bill11 said:

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.

Click to expand...

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

We have a Dometic Series T diaphragm waste pump. Works like a charm, and is very quiet.

RickB said:

"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)

Click to expand...

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

psneeld said:

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.

Click to expand...

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

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).

N4712 said:

We have a Dometic Series T diaphragm waste pump. Works like a charm, and is very quiet.

Click to expand...

Maybe I will get one of those Dometic pumps when my current one takes a sh&t.

ranger42c said:

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?

Click to expand...

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.

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.

Click to expand...

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.

FF said:

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.

Click to expand...

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.

N4712 said:

We have a Dometic Series T diaphragm waste pump. Works like a charm, and is very quiet.

Click to expand...

What he said.

Capt.Bill11 said:

What he said.

Click to expand...

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.

The Whale Gulper is said to be another good diaphragm pump for shower sumps, waste pumping, etc.

Marin said:

The Whale Gulper is said to be another good diaphragm pump for shower sumps, waste pumping, etc.

Click to expand...

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.

RickB said:

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.

Click to expand...

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.



-Chris

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?

ranger42c said:

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."

Click to expand...

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.

what_barnacles said:

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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WOW

Really WB as much as she has helped many on TF

RickB said:

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 ****.

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.

Click to expand...

Rick your right and very good point

siestakey said:

Rick your right and very good point

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Thank you.

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.

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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.

caltexflanc said:

(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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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.

RickB said:

"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."

Click to expand...

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.

-Chris

psneeld said:

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?

Click to expand...

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