Wastewater Holding Tank Questions

Troy Scott · Post by **Troy Scott** » Oct 22nd, '11, 11:25

Folks,

Not really giving advice here, just throwing out a few thoughts:

1. The pickup tube on my CD36 touches the bottom of the tank, and is cut off at about a 30 degree angle. In fact it more than "touches"; it's firmly pressed to the bottom when the fitting is well screwed in to the top of the tank. The pickup tube is a plastic tube that fits into the PVC fitting that is screwed in to the top. This is an odd arrangement of parts that just "happen to fit", something Cape Dory came up with, but it works fine.

2. I have no "Y" valves. When the boat came into my life, she had one Y valve for selecting head directly to ocean or head to holding tank. I eliminated that valve. I also eliminated the through-hull and seacock in the head area. I repaired the hole in the hull. Everything from the head now goes to the holding tank. The boat came with a cabin sole mounted pump-out fitting for using dockside pump-out stations. She also had a manual pump and a seacock for pumping the contents of the holding tank directly overboard.

3. There was/is no "Y" valve on the pump-out side of the tank, nor is there a need for one. There is only a "Y" FITTING in the line from the tank. One side of the Y goes to the deck mounted pump-out connection. The other side of the Y goes to the pump for pumping to the ocean through the seacock. If the dock-side pump-out is in use, the sewage comes out of the tank, and it would with or without a Y-valve. If the sole-mounted pump-out fitting is closed and the pump is being used to move the holding tank contents into the ocean, the sewage moves from the HT to the ocean, and it would with or without a Y-valve.

In conclusion, it's perfectly obvious why a Y-valve would be appropriate if the choice is ocean or holding tank. However, there is no need for a Y-valve on the pump-out side. Various aspects of the system obviate the need. For example:

1. Practically all bilge and/or pump-out pumps utilize a "flapper" or "joker" valve which functions as a one-way valve.

2. Even if the one-way valve, for whatever reason didn't function, the seacock is still closed, so that only leaves the tiny, and thus inconsequential vent hole in the anti-siphon loop between the manual pump and the seacock.

In short, there is no way for sufficient air to enter the system to keep either a dockside pump-out station or a pump-out to the ocean from working well, and there is no need for a Y valve. Installing a Y-valve instead of a Y fitting at this point just complicates the procedure when it's time for emptying the holding tank.

Also, as an aside, the barbless hose fittings in question are very high-quality glass-filled nylon, especially made for the best sewage hose.

sfreihofer · Post by **sfreihofer** » Oct 22nd, '11, 23:00

John;

Hmmmm. I think you're over my head. I need to go lie down (horizontal) and air out my brain...

Stan

sfreihofer · Post by **sfreihofer** » Oct 23rd, '11, 00:00

Troy;

Like your system, all waste from my head goes to my holding tank. Where it goes from there (overboard vs. pumpout) could functionally be accomplished with a Y fitting, as you describe.

Legally, however, I don't believe it is adequate because within 3 miles of the coast, any overboard dump of human waste is illegal.

From my understanding, while the Y fitting is functionally adequate, it is not legal because a lockable Y valve is required to eliminate the overboard dump option when near shore. The Coast Guard enforces this requirement.

Stan

Russell · Post by **Russell** » Oct 23rd, '11, 09:37

A lockable Y valve I believe is only required for direct discharge from the head. I have never heard of it being required on optional discharge from the holding tank. Most boats I have ever seen (mine included) that can pump the holding tank overboard have a simple Y (not a valve) as described by Troy.

johnc · Post by **johnc** » Oct 23rd, '11, 12:27

I like the simplicity of the Y-fitting over the Y-Value.

My concern with using the Y-fitting lies not so much in its legality as in the interpretation of its legality.

It seems to me that one day the Coast Guard might say it's OK and the next they give you a ticket. Down here in the Keys there is a very active campaign to eliminate live-a-boards. The head is one of the "excuses" the local authorities, Coast Guard and Florida Fish and Wildlife Conservation Commission (FWC), are going after to remove live-a-board boats and when the local authorities make a judgment decision it's not likely to be on the side of the boat owner.

Russell · Post by **Russell** » Oct 23rd, '11, 12:52

You know John, you may have a very valid concern there. I went and looked up the law itsself, and basicly it seems to say that any means of discharging untreated waste overboard should be locked. It would be pretty easy to interpret this as including the holding tank discharge (in fact, reading it, I think it flat out does include it, no interpretation nessisary). I think to date the holding tank discharge pumps just have generally not been looked at and enforced, but nothing would prevent them from doing so.

So a Y valve here would not be a bad idea afterall, it makes securing the holding tank discharge easy. Otherwise one would need to find a way to lock the seacock itself in a closed position, which I dont see any way to do with my holding tank seacock. Though one legal and valid option to secure it is to close the seacock and remove the handle.

Having thought this through more and looking at the law, I think if doing a new system from scratch, or redoing an existing system, the Y valve makes sense. If wanting to just quickly make a system legal remove the seacock handle for now (ie if suddenly you hear through the grapevine that enforcement has begun).

Here is the applicable section of the actual law by the way: http://frwebgate.access.gpo.gov/cgi-bin ... &TYPE=TEXT

Russell · Post by **Russell** » Oct 23rd, '11, 12:58

On a different topic, if you have not yet bought your sanitation hose, I strongly recommend using Trident "Sani Shield" hose, its much more flexible and easier to work with then traditional pvc sanitation hose.

Product #102 on this web page: http://www.tridentmarine.com/stage/sanitation.htm

Defender carries it, west marine does not last I checked.

Steve Laume · Post by **Steve Laume** » Oct 23rd, '11, 12:59

Why couldn't you simply add a wire tie or other locking device to the seacock handle? Epoxy a pad eye to the hull and you are good to go, Steve.

Russell · Post by **Russell** » Oct 23rd, '11, 13:02

Steve Laume wrote:Why couldn't you simply add a wire tie or other locking device to the seacock handle? Epoxy a pad eye to the hull and you are good to go, Steve.

That certainly seems a valid approach to making an existing system legal.

sfreihofer · Post by **sfreihofer** » Oct 23rd, '11, 13:36

Hi Russell;

I'm not an attorney, but I assume overboard discharge must be disabled, regardless of the source (head, or tank), because the regulations do not differentiate between sources.

One of the controlling Federal regulations is 33 CFR 159.7, which is the Coast Guard regulation to enforce the EPA regulations. It states in Section (c) (The underline is my added emphasis):

(c) When operating a vessel on a body of water where the discharge of untreated sewage is prohibited by the Environmental Protection Agency under 40 CFR 140.3, the operator must secure each Type III device in a manner which prevents discharge of sewage. Acceptable methods of securing the device include--
(1) Closing each valve leading to an overboard discharge and removing the handle;
(2) Padlocking each valve leading to an overboard discharge in the closed position; or
(3) Using a non-releasable wire-tie to hold each valve leading to an overboard discharge in the closed position.

[CGH 95-028, 62 FR 51194, Sept. 30, 1997]

The acceptable methods listed are not exclusive of other methods, but the requirement intends to disable overboard discharge of sewage. To me, a lockable Y valve is the simplest solution.

I would be glad if I'm wrong...

Stan

sfreihofer · Post by **sfreihofer** » Oct 23rd, '11, 14:20

Russell: Though one legal and valid option to secure it is to close the seacock and remove the handle.

I agree. From my understanding of the regs, this would meet the legal requirement.

The hardware requirement is kind of silly, but the penalties are quite stiff.

Troy Scott · Post by **Troy Scott** » Oct 23rd, '11, 21:57

This is a good and important discussion. My solution was/is to use an ordinary padlock to prevent opening the seacock. Based on previous similar discussions and my own reading of the regulations, only the operator of the boat, who is ultimately responsible anyway, should have access to the key.

To be fair, unlocking the seacock is a necessary step that takes no less time than unlocking a Y-valve. My point in my earlier post was to clarify that there is no PLUMBING requirement for a Y-valve as opposed to an ordinary Y fitting. It is just another means of complying with the regulation that requires a means of preventing overboard discharge of holding-tank contents. In my case the seacock lock is easier to reach.

Part of this discussion should include the discharge of pollutants other than sewage. The operator can be fined if, for example, oil leaks into the bilge and is later deliberately or inadvertently, maybe even automatically pumped overboard. I have also heard that in some places, detergents washed into the water from just cleaning the decks can be grounds for a fine.

sfreihofer · Post by **sfreihofer** » Oct 24th, '11, 10:56

Troy Scott wrote: My point in my earlier post was to clarify that there is no PLUMBING requirement for a Y-valve as opposed to an ordinary Y fitting. It is just another means of complying with the regulation that requires a means of preventing overboard discharge of holding-tank contents.

Yes. You are correct.

I have also read that if you must engage two (or more) switches simultaneously to dump overboard on a recreational boat, that also meets the legal requirement. If you use that method, you may want to carry a copy of this letter: http://newboatbuilders.com/docs/16750_MSDs_USMarine.pdf

Stan

sfreihofer · Post by **sfreihofer** » Oct 24th, '11, 11:29

There are also State regulations which apply. I found the Florida regulations here: http://www.law.ufl.edu/conservation/pdf ... tation.pdf
and here: http://www.dep.state.fl.us/cleanmarina/ ... er_faq.htm

What a load of crap! Pun intended.

Stan

Troy Scott · Post by **Troy Scott** » Oct 24th, '11, 12:18

Otherwise known as "Pollution and Other Obnoxious, Political and Odious Obstructions" to our boating simplicity and pleasure (P.O.O.P.O.O.).
The agencies responsible for C.R.A.P. and P.O.O.P.O.O. are busy-busy and up to their knees (or higher) in the fundamental aspects of nature they would like to regulate even more thoroughly. I suspect they will soon create even more rules, because at present there is a huge void in the regulations: We have NO IDEA where fish, marine mammals and other aquatic life are free to release the contents of their "holding tanks".

I'm excited about seeing many of you at the Annual Meeting at the Fairhope Yacht Club!

The Cape Dory Board

Wastewater Holding Tank Questions

My Holding Tank Plumbing

Y-Value Requirement

preventing overboard discharge

Re: preventing overboard discharge

Cantankerous Regulations About Pollution (C.R.A.P.)