Discharge Rules

[ROBERTH]

Ok, got to ask for clarification.

I think on my model boat, the 252G with head installed and holding tank, it is classified as a Type 1 system?

Trying to figure out some of the rules. Reason I am asking is I had posted in the past that I had a 1 1/2" hose and Y-valve that I was not sure how it worked or what it's purpose was.
This week, I had the cabin floor panels up and decided to investate. Long story short, I removed the hose from the Through Hull and removed the seacock valve since I could not run a snake through it. I found that the handle stem where it connects to the bronze ball was disentigrated, thus when turning the handle, the ball was not rotating, so I could never open it. So now, I see that the Y-Valve will allow direct discharge through this 1 1/2" hose and through hull and bypass the holding tank.
I am replacing the seacock with a new one, but now that it will be functional, I was reading where the Y-Valve has to be physically locked when inshore of the 3 mile limit? Or, I have to padlock access to the valve, which I could do with the small access door by installing a lockable hasp I suppose, being that my Y-Valve is not the type to accept a lock.
It seems that this system is legal, if I have secured the Y-valve as defined and only time I open it is outside the 3 miles.

Does this sound right? Who knows for sure? Is there any other acceptable method of securing the valve if that is the case? Just sounds to me like the valve not open is not acceptable.

 

[wspitler]

I believe yours is a Type III MSD. As an Ex-USCG boarding officer here's what we went by:

"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. Adequate means include the use of padlock, non-releasable wire-tie, or removal of the valve handle. For more information see 33 CFR 159.7."

I'd go for the wire tie if it was me. Check this website for details: http://www.uscg.mil/hq/cg5/cg5213/msd.asp My 330 has a key that controls the pump and the seacock has no securing capability. That is a USCG approved installation. Also note that US territorial waters can go out to 12 miles from the baseline.

 

[ROBERTH]

Thanks Bill, that is the website that I was reading and re-read and seems it would fit in the Type III. Was referring to incineration and other methods that threw me off.

So, the 3 miles out is Federal whereas the 12 miles is US Territorial? I had never realized this. Was thinking everything was the 3 miles out rule.

With that, and correct me if above is wrong or tell me more about it.... I need the waste rules for dummies version.....

Thinking, where it says this: the valve must be positively secured in a way that presents a physical barrier to valve use and prevents all discharges. Adequate means include the use of padlock, non-releasable wire-tie, or removal of the valve handle.

The part on where it says "Presents a physical barrier to valve use". Wouldn't that be that the Seacock is in off position under a popup type deck plate on the floor, and the Y Valve is behind a panel with a door that is secured with a hook latch. Now, if I put a pad lock on the door in place of the hook latch, seems to me that would suffice as a "Physical barrier to valve use preventing all discharges?

Then, assuming I did not use or have the 1 1/2" discharge but instead had only the macerator, that valve is also under the floor deck plate and in closed position, which is the "Grady" original design and installation. So with that, thinking that the deck plate is approved as a physical barrier to valve use as well? Else, Grady is not in compliance?

Not being sarcastic in any way, just thinking this through as if in a debate. :hmm

 

[wspitler]

I think anything reasonable will pass a boarding officer's inspection. I don't know about local and state guys, but we (I) never worried about the security as long as the seacock or other control valve was closed. I'm sure that Grady wouldn't put out a design that didn't meet the requirements. For boats our size, MSDs are not usually an issue during a boarding or inspection. If you're worried, wrap some stainless wire around the handle of the valve, that is easy to remove and actuate. You could even label the valve with a sign warning not to open in territorial waters. I believe the design requirement is to prevent accidental or inadvertent discharge, not a willful violation. A lock or other physical barrier won't prevent a willful violation. We need to be able to pump when it's legal to do so.

 

[lgusto]

Let me start by saying that my post is a bit off the OP's question, but close enough to the topic to warrant inclusion.

Next, I confess to begin a "rules junkie", not because I enjoy it but rather out of necessity as a charter captain and commercial fisherman.

Reading

Also note that US territorial waters can go out to 12 miles from the baseline.

threw me for a loop since it has always been my understanding that you could dump a head outside of the three mile line. Researching a few minutes came up with this from 33 CFR 159.3 - Definitions:

"Territorial seas means the belt of the seas measured from the line of ordinary low water along that portion of the coast which is in direct contact with the open sea and the line marking the seaward limit of inland waters, and extending seaward a distance of 3 miles."

With all due respect to the ex-boarding officer, I still believe we can discharge outside of three miles. Thoughts?

 

[wspitler]

lgusto, You are right in almost all instances. Been a long time since I really knew the law and I never was a sea lawyer. I do remember the trainers warning us that due to baseline issues, territorial seas could go out to (by international convention) a maximum of 12 miles. I seem to remember in places with indentations in the coast, I'm thinking Florida Bay, it could go out to 12 miles. I also found that in 1988 the President extended US "territorial waters" to 12 miles. I don't know if that is the same. I think it's pretty complicated as most lawyer things are and that's why I put in the warning. I think the EPA even uses the word navigable waters, probably to include more inland stuff. There is probably a map somewhere if anyone wants to look it up. I just didn't want someone to get busted at 4 miles when a baseline issue existed.

 

[Legend]

All the times I have been boarded by the Coast Guard they have never inspected the discharge valve. Three years ago I did have a CG Auxillary courtesy inspection and was told that some local enforcement (Plymouth) routinely inspect to ensure a secured valve. He said ideally a padlock but a wire tie would cover you. Seems dumb since my valve has a tag that identifies it as head discharge- but a pretty easy regulation to cover with a wire tie

 

[ROBERTH]

I found this information that seems to clarify it more. Sounds like a "physical barrier" would pass in my case I am hoping in that it is a door panel that is latched and the "Y" valve is secured behind the door.
The only other thing I can do is to secure it with a padlock to prevent access behind the "physical barrier" without a combination or key to unlock the padlock, but seems that might be overboard a bit in how this is defined. A wire tie is stated as a "non re-sealable" tie. What is that? My problem in using a wire tie of any sort is how difficult it would be to access it behind the barrier as it is a bit of a challenge to get to it, especially with 2 hands.

Below web site has this section pasted below: http://www.maritimesanitation.com/maritime.php?ID=24
Marine Sanitation Devices
The Federal Clean Water Act requires that all boats with an installed head have one of three types of Coast Guard approved marine sanitation devices (MSD's) attached to the toilet. Failure to comply can result in a $2,000 fine. Type I and II MSD's are flow-through systems that treat the sewage using chemical, electrical and/or incineration methods before discharging the waste overboard; i.e., Lectra-San or Microphor. A macerator pump is not an MSD. Type III MSD's are holding tanks that store sewage on the boat. The waste is not treated in a Type III device, even if odor-reducing chemicals are added. It is illegal to discharge or empty the contents of your boat's holding tank in U.S. territorial water ( within a three-mile limit). Some boats are equipped with a "Y" -valve that allows for the direct discharge of raw sewage. This valve can only be used outside the three-mile limit. Coast Guard regulations require that the "Y"-valve must be secured in the closed position (by padlock, non-resealable tie, removal of handle or other physical barrier) when the boat is within three miles of shore. Boaters can be fined for non-compliance.