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Discussion Starter #1
Our heads all empty to a central holding tank. There are no Y-valves for the heads to discharge directly overboard, nor is there a gravity drain for the holding tank. It must either be pumped out through the deck fitting or discharged overboard, via an electric macerator pump and valved thru-hull. I zip tie the handle on the thru hull to comply with USCG requirements that the overboard discharge be disabled in NDZs.

I understand that simply shutting off the breaker does not comply with the disabling requirement. I would not leave the valve open anyway, for water ingress safety, but doing so would not allow for the the tank to empty. The pump must be activated.

The switch that turns the pump on and off is a single press on, single press off switch that is inside one of the heads. Specifically the one, which has the valved thru hull beneath it's counter. It's identical to the one that turns the lights on and off in that head. Very bad placement. I have a label over it, to try to prevent guests from accidentally turning it on. I keep the pump's breaker off at the panel, but a guest accidentally clicks the switch once, it goes to the On position for the next time I turn the breaker on. That's a problem, but I don't go open the thru-hull, then return to breaker.

Long way of getting to the idea of putting a keyed on/off switch in place of the single press switch. The idea is to avoid accidental manipulation by guest. However, I got to wondering if this alone would comply with USCG disabling requirements and I could get out of the repeated zip tie business. I would remove the key and store elsewhere, so there is no way to discharge overboard without it. What do you think?
 

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Looks likely to be acceptable in my opinion - not that it counts for much. "considered to be sufficient in most cases." - means nothing is sure.


No discharge zone.
While operating a vessel in an EPA designated no discharge zone, flow-through devices are only permitted if adequately secured to prevent discharges of all treated and untreated sewage. For example, closing the seacock and padlocking, using a non-releasable wire tie, or removing the seacock handle are considered to be sufficient in most cases. For short voyages, locking the door to the head with a padlock or a door handle key lock is another acceptable method. For vessels that routinely operate in no discharge zones a Type III MSD is recommended. For more information see 33 CFR 159.7 and 40 CFR Part 140
 

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Discussion Starter #3
.....flow-through devices are only permitted if adequately secured to prevent discharges of all treated and untreated sewage.
Thanks for the references. The Coast Guard's website and the actual entry in the CFR read a little differently. The above quote is from the USCG and says "adequately secured"

For more information see 33 CFR 159.7 and 40 CFR Part 140
The CFR says.......

Acceptable methods of securing the device include -

(1) Closing the seacock and removing the handle;
(2) Padlocking the seacock in the closed position;
(3) Using a non-releasable wire-tie to hold the seacock in the closed position; or
(4) Locking the door to the space enclosing the toilets with a padlock or door handle key lock.
The CFR says "include", which does not specify that there aren't more acceptable methods.

I think I'm going to take my chances with a key locked pump switch (key removed, thru hull closed but not secured). If the Coasties are standing there and saying it's non-compliant, I'll ask them how they would discharge, if they tried.
 

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I would not leave the valve open anyway, for water ingress safety, but doing so would not allow for the the tank to empty. The pump must be activated.
I know that this is a peripheral question, but I'm wondering if you have an anti-siphon on the hose from macerator to through-hull. (ABYC calls for a loop above the waterline with anti-siphon, though many boats - including mine - do not have it.) If you do not have an anti-siphon valve, then leaving the valve open might suck the contents out when underway by the Bernoulli effect (slowly, since it would have to creep through the stationary impeller). Technically, then, this might require you doing the zip ties or lock, but I'm not looking to push that argument (or make an example of myself).
 

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Deleted accidental post...
 

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I found padlocking the thru hull the easiest solution. I glued a bloc of wood to the inside of the hull, below the thru-hull handle, added a u-bolt and bought a long shaft lock that went over the handle and thru the u-bolt. If you cannot open the thru-hull then nothing should get out. I have heard they drop dye in your toilet and have you run around to see if any of it comes out. If they can open the thru-hull (assume it is accidentally left open) then you might have a leak.
 

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Our discharge goes through a lockable marlon Y valve. Simple padlock with a key. Coast Guard checked us out once and it met their approval. Drift: they also looked for the discharge placard too.


 

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Discussion Starter #8
I know that this is a peripheral question, but I'm wondering if you have an anti-siphon on the hose.....
Yes, the macerator pump is at the base of the holding tank, but then pumps the effluent up to a vented loop, before returning down to the thru-hull. Good point, if one did not have this. Without it, one might expect it to even gravity drain, with the thru-hull open, at certain heel angles.
 

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Discussion Starter #9
I found padlocking the thru hull the easiest solution. I glued a bloc of wood to the inside of the hull, below the thru-hull handle, added a u-bolt and bought a long shaft lock that went over the handle and thru the u-bolt. If you cannot open the thru-hull then nothing should get out.
In my case, I need some sort of safety on the switch that activates the macerator discharge pump, regardless of NDZ laws. With the thru-hull closed, I never want the pump to be activated, else it may create enough hose pressure to cause a leak. Yuk. I'll put the keyed switch for the pump, either way, so I'm thinking it should suffice as "adequately secured". In all candor, there is no way anyone could get it to discharge, without the switch key.

I have heard they drop dye in your toilet and have you run around to see if any of it comes out. If they can open the thru-hull (assume it is accidentally left open) then you might have a leak.
If I got hassled, I'll remember to encourage them to give this a try. All heads are plumbed exclusively to the same holding tank, that is down in the bilge. Effluent simply can't escape, up the vented loop, without the pump activated.
 

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I believe that the key solution works. I deliver a boat annually that uses that set-up. He leaves the key in, but, obviously it could be locked and removed.
 

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I have a manual pump for pumping the tank that I remove the handle from and I keep the overboard valve closed. I was boarded a few years ago by the USCG and they said valve should really still be locked, though they didn't make a big deal about it. Didn't appear on the written form they gave me after the boarding.
 

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Discussion Starter #12
I have a manual pump for pumping the tank that I remove the handle from and I keep the overboard valve closed. I was boarded a few years ago by the USCG and they said valve should really still be locked, though they didn't make a big deal about it. Didn't appear on the written form they gave me after the boarding.
Typical bureaucracy. Removing the handle is literally the first example of what’s acceptable in the regulation.

I never liked the option, for my setup, worried that dropping the handle would disappear below inaccessible flooring.
 

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You could replace the thruhull with one of these: Monitored Ball Valve (Tru Design Valf Product)

Wire it through a solenoid to your switch, and the switch will be automatically locked out when the valve is closed.

Alternately, couldn't you replace the switch with a type that is obvious which state it is in? The easy answer is move the switch, but I'm assuming that would leave an unsightly hole or you would have done it.

Mark
 

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Typical bureaucracy. Removing the handle is literally the first example of what’s acceptable in the regulation.

I never liked the option, for my setup, worried that dropping the handle would disappear below inaccessible flooring.
Talking about the pump handle, not for the overboard thru hull valve. But still would take someone to open the valve, find the handle, and start pumping. Not something that would happen accidentally.
 

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Replace the switch in the head with a momentary on switch.
 

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I know that this is a peripheral question, but I'm wondering if you have an anti-siphon on the hose from macerator to through-hull. (ABYC calls for a loop above the waterline with anti-siphon, though many boats - including mine - do not have it.) If you do not have an anti-siphon valve, then leaving the valve open might suck the contents out when underway by the Bernoulli effect (slowly, since it would have to creep through the stationary impeller). Technically, then, this might require you doing the zip ties or lock, but I'm not looking to push that argument (or make an example of myself).
My boat does not have an anti-siphon loop either. The through hull seacok for my macerator is ALWAYS closed (and usually secured with zip-ties) unless I am running the macerator. I have a current, mandatory, RI NDZ Compliance sticker.

In order to run my macerator, I have to flip the breaker to "ON" at the companionway, then go forward to the V-berth, lift the cushions, open the access panel, open the seacok, flip the momentary switch to "ON," and hold it until the holding tank is empty (judge this by the tank monitor light going green, and the macerator running faster with no load). I then release the switch, close the valve, close the access panel, put the cushions back, and then go back to the companion way and flip the breaker to "OFF."
 

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Discussion Starter #19
Replace the switch in the head with a momentary on switch.
That would help my primary complaint of a guest accidentally turning it on. However, our central holding tank is 77 gallons and can take as much as 10 minutes to empty. Too long to hold a momentary button.

Besides, I'm really liking the unintentional 'kill two birds with one stone' approach of the keyed switch. No guest problems and NDZ compliance. Although, as you raised RI's unique law, they only list three acceptable solutions: "waste must be pointed toward the holding tank and secured in place – by removing the handle, padlocking it, or affixing a non-releasable wire tie". Federal law seems say other methods could comply.

I have to say, very few RI boats seem to have the compliance sticker, which is a stupid bureaucracy anyway. Nothing about someone seeing one's zip tie or handle removed means it will be affixed the next day. It may catch the very rare vessel that has no seacock at all, but then why would they bother having it inspected. Ironically, if one's boat has multiple heads (ours has 3), the fine for not having the sticker is barely more than the inspection fee. I pay. I pay my $600+ registration fees too. However, I really doubt half the boats do. I know some who had been in the marina for a decade and never realized there was a RI state registration for USCG documented vessels.
 
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