MSD's Anyone? Have just had my Beneteau 311 head "approved" by the Alabama Marine Police in Mobile. I got the macerator installed in the new boat to empty the holding tank thinking that I was getting a type I MSD. I am using West Marine's blue fluid. Was told by the officer that even though my tank and macerator are pro forma a type I MSD, I was only "approved" as a type III (holding tank with Y-valve locked). When pressed, the reply was, "that was what we were told by the Coast Guard briefing officer." It seems that the requirement is for some kind of chemical to kill the coliform bacteria (hereafter, "bugs"). The Marine Police agreed that a Lectro-San unit, which electrically decomposes the sea salt molecules into sodium and chloride ions, the latter of which kill the bugs, is a type I MSD. West's fluid contains a "quaternary ammonia compound," from the Material Data Sheet. Apparently the ammonia compound in the blue juice is a nitrogen-rich fertilizer causing some kind of digesting action on the sludge in the tank and hoses, thus deodorizing them. Digesting action is the mode of operation of a type II MSD. My question is, how much 5% sodium hypochlorite bleach would I have to use per gallon of waste to chemically ensure the killing of the coliform bugs, and thus claim a type I MSD? Why is this so important? Because next year, or the year after, they'll be back claiming that there are NO approved type I MSD's in Alabama waters, and therefore they can get a NO DISCHARGE DESIGNATION for all Alabama waters, just like Rhode Island and Chesapeake Bay.
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Dr., Peggie can help you. She might see your
question sooner if you post to her board at 'Head Mistress'.
question sooner if you post to her board at 'Head Mistress'.
Hooboy...a whole lot of confusion here.
The water cop needs a LOT more training...a holding tank and macerator, no matter what's used in the tank, is NOT a Type I MSD--"approved" or otherwise--by ANY definition...it's just a holding tank (Type III) that can either be pumped out or dumped overboard (but only at sea beyond the "3 mile limit"--which is NOT just 3 miles from the nearest shore in a bay, harbor or lake, but in any waters within 3 miles of the nearest point on the whole US coastline. There is nothing that can be added to a holding to make it legal to dump it inside the "3 mile limit." Reason: not only must the bacteria count be <1000/100 ml, but the waste must be macerated much more completely than any overboard discharge pump can do as waste just passes through it. All Type I’s and Type II’s must must be certified in prototype by the mfr by the CG and will have a Coast Guard Certification label, affixed by the manufacturer attached to it. The label must show the name of the manufacturer, the name and model number of the device, the month and year of manufacture, the type of MSD, a certification number and a certification statement. If there is no label, the device is not a CG Certified MSD (treatment device). Only waste that is treated by a Coast Guard Certified Type I or Type II MSD is considered “treated" waste; there is nothing that can be added to a holding tank that will make it legal dump the tank. In fact, even if the waste has been through a CG certified treatment device before going into a holding tank, the tank still cannot legally be dumped. Nor can a boat owner design and use his own treatment device; even if it does meet all the legal requirements, only devices submitted to the Coast Guard by equipment manufacturers who then must manufacture every unit exactly to the certified specifications, are legal "approved" Type I or II MSDs. The Raritan Lectra/San is a CG certified Type I MSD...legal for use in all waters that have not been specifically designated "no discharge." I don't think you have to worry about Mobile Bay becoming a "no discharge" zone...the AL marine sanitation law, which took 'em several years to write, is still so poorly written that it's unenforceable on inland waters. Mobile Bay is an interstate navigable waterway, under the jurisdiction of the CG, with enforcement authority also given to a state agency. Neither the CG nor any agency can just decide that any device is or isn't "approved"...that's determined by federal law...and unless the state can convince the EPA that there are ecological reasons why the whole state--including Mobile Bay--should be declared "no discharge," it ain't gonna happen. So if you don't want to mess with maintaining and pumping out a holding tank, install a Lectra/San. You'll find all the specs for it including the installation, operation and maintenance manual on the Raritan website at http://www.raritaneng.com Btw...all the waters of RI are "no discharge," but with the exception of only two very small harbors--the "northern coastal bay" and Herring Bay--the Chesapeake Bay is not. In fact, the ONLY "no discharge" waters of any size south of RI on the whole east coast and Gulf of Mexico are the FL Keys and Destin Harbor...Type I and II MSDs are legal in all others. You'll find a listing of all coastal and most inland "no discharge" waters in the whole US on the EPA site at http://www.epa.gov/owow/oceans/regulatory/vessel_sewage/vsdnozone.html If you have any more questions, I'll be glad to answer 'em. Meanwhile, you may also find the link below has information you can use. Btw, Fred...I don't only read "my" forum...if I did, I'd miss at least half the "potty" and odor questions, 'cuz the HM forum seems to be the last place it occurs to anyone to ask sanitation questions. Instead, I scroll through all the posts from the last 24 hours. Takes all of about 30-60 seconds to get through the ones posted since the last time I checked...I wish everyone would do that, 'cuz it would prevent asking questions in one forum about something that's already being discussed in another one.
The water cop needs a LOT more training...a holding tank and macerator, no matter what's used in the tank, is NOT a Type I MSD--"approved" or otherwise--by ANY definition...it's just a holding tank (Type III) that can either be pumped out or dumped overboard (but only at sea beyond the "3 mile limit"--which is NOT just 3 miles from the nearest shore in a bay, harbor or lake, but in any waters within 3 miles of the nearest point on the whole US coastline. There is nothing that can be added to a holding to make it legal to dump it inside the "3 mile limit." Reason: not only must the bacteria count be <1000/100 ml, but the waste must be macerated much more completely than any overboard discharge pump can do as waste just passes through it. All Type I’s and Type II’s must must be certified in prototype by the mfr by the CG and will have a Coast Guard Certification label, affixed by the manufacturer attached to it. The label must show the name of the manufacturer, the name and model number of the device, the month and year of manufacture, the type of MSD, a certification number and a certification statement. If there is no label, the device is not a CG Certified MSD (treatment device). Only waste that is treated by a Coast Guard Certified Type I or Type II MSD is considered “treated" waste; there is nothing that can be added to a holding tank that will make it legal dump the tank. In fact, even if the waste has been through a CG certified treatment device before going into a holding tank, the tank still cannot legally be dumped. Nor can a boat owner design and use his own treatment device; even if it does meet all the legal requirements, only devices submitted to the Coast Guard by equipment manufacturers who then must manufacture every unit exactly to the certified specifications, are legal "approved" Type I or II MSDs. The Raritan Lectra/San is a CG certified Type I MSD...legal for use in all waters that have not been specifically designated "no discharge." I don't think you have to worry about Mobile Bay becoming a "no discharge" zone...the AL marine sanitation law, which took 'em several years to write, is still so poorly written that it's unenforceable on inland waters. Mobile Bay is an interstate navigable waterway, under the jurisdiction of the CG, with enforcement authority also given to a state agency. Neither the CG nor any agency can just decide that any device is or isn't "approved"...that's determined by federal law...and unless the state can convince the EPA that there are ecological reasons why the whole state--including Mobile Bay--should be declared "no discharge," it ain't gonna happen. So if you don't want to mess with maintaining and pumping out a holding tank, install a Lectra/San. You'll find all the specs for it including the installation, operation and maintenance manual on the Raritan website at http://www.raritaneng.com Btw...all the waters of RI are "no discharge," but with the exception of only two very small harbors--the "northern coastal bay" and Herring Bay--the Chesapeake Bay is not. In fact, the ONLY "no discharge" waters of any size south of RI on the whole east coast and Gulf of Mexico are the FL Keys and Destin Harbor...Type I and II MSDs are legal in all others. You'll find a listing of all coastal and most inland "no discharge" waters in the whole US on the EPA site at http://www.epa.gov/owow/oceans/regulatory/vessel_sewage/vsdnozone.html If you have any more questions, I'll be glad to answer 'em. Meanwhile, you may also find the link below has information you can use. Btw, Fred...I don't only read "my" forum...if I did, I'd miss at least half the "potty" and odor questions, 'cuz the HM forum seems to be the last place it occurs to anyone to ask sanitation questions. Instead, I scroll through all the posts from the last 24 hours. Takes all of about 30-60 seconds to get through the ones posted since the last time I checked...I wish everyone would do that, 'cuz it would prevent asking questions in one forum about something that's already being discussed in another one.
One more question, if you have a minute...
I read a few years back about a guy who had invented a new system that took the grey and black water, ran them through a macerator and then injected them under high pressure into the exhaust manifold of a running diesel engine. Seems the high temperature of the exhaust manifold immediately turns the waste to steam and a very fine ash that was completely sanitary and germ free. The whole operation was controlled by a small computer chip that sensed flow rates, engine temperature, etc. If I remember right, the device could dispose of 4-5 gallons of waste per hour of engine running time and caused no harm to the engine. Seemed like a really nifty idea that would be fairly easy to retrofit to an existing set-up. Have you heard anything about this system? Will it be coming to market soon? All he had at the time of the article was a prototype, so I'm wondering if he ever went anywhere with the idea. Thanks, Jeff
I read a few years back about a guy who had invented a new system that took the grey and black water, ran them through a macerator and then injected them under high pressure into the exhaust manifold of a running diesel engine. Seems the high temperature of the exhaust manifold immediately turns the waste to steam and a very fine ash that was completely sanitary and germ free. The whole operation was controlled by a small computer chip that sensed flow rates, engine temperature, etc. If I remember right, the device could dispose of 4-5 gallons of waste per hour of engine running time and caused no harm to the engine. Seemed like a really nifty idea that would be fairly easy to retrofit to an existing set-up. Have you heard anything about this system? Will it be coming to market soon? All he had at the time of the article was a prototype, so I'm wondering if he ever went anywhere with the idea. Thanks, Jeff
It's come and gone--at least twice
The first time was about 15-20 years ago in the RV market. Not only did the exhaust stink, but the animal fats in waste built up in the exhaust pipe and catalytic converter. Several years ago a European company actually did put in on the market for boats--even got it CG certified as a Type I...Powerboat Reports (sister publication to Practical Sailor) even did a review of it. However, it didn't even last as long in the marine market as it did in the RV market. First, it created the same problem in boat exhausts that it in vehicle exhausts...second, it only works in boats that have above waterline dry exhausts...water exhausts don't get hot enough, Third, it cost about $15k. That leaves a VERY limited market for it. Even without all those issues, it would hardly be a practical solution on a sailboat 'cuz you'd have to run the engine a lot to empty the tank...what if the tank gets full in the slip--do you turn on the engine and let it run for several hours? It wouldn't be legal in "no discharge" waters either, 'cuz whether waste is treated chemically or reduced to ash, it's still considered waste under the law. There very well may be others who've tried to develop the same idea...'cuz a lot of people have tried--and more WILL try--to find new and better ways to deal with onboard waste, but so far nobody's been able to improve on the Lectra/San--not even Raritan, who makes the L/S (except for the controller, it hasn't changed in 25 years)--when it comes to being able to legally send waste overboard in waters where the discharge of treated waste is legal.
The first time was about 15-20 years ago in the RV market. Not only did the exhaust stink, but the animal fats in waste built up in the exhaust pipe and catalytic converter. Several years ago a European company actually did put in on the market for boats--even got it CG certified as a Type I...Powerboat Reports (sister publication to Practical Sailor) even did a review of it. However, it didn't even last as long in the marine market as it did in the RV market. First, it created the same problem in boat exhausts that it in vehicle exhausts...second, it only works in boats that have above waterline dry exhausts...water exhausts don't get hot enough, Third, it cost about $15k. That leaves a VERY limited market for it. Even without all those issues, it would hardly be a practical solution on a sailboat 'cuz you'd have to run the engine a lot to empty the tank...what if the tank gets full in the slip--do you turn on the engine and let it run for several hours? It wouldn't be legal in "no discharge" waters either, 'cuz whether waste is treated chemically or reduced to ash, it's still considered waste under the law. There very well may be others who've tried to develop the same idea...'cuz a lot of people have tried--and more WILL try--to find new and better ways to deal with onboard waste, but so far nobody's been able to improve on the Lectra/San--not even Raritan, who makes the L/S (except for the controller, it hasn't changed in 25 years)--when it comes to being able to legally send waste overboard in waters where the discharge of treated waste is legal.
Peggie, you're good!
Thanks much for the complete answer to my post. Very illuminating. Apparently the Marine Police officer did the right thing, but now I feel I've wasted a lot of money on the macerator. I fault the Beneteau people for not making "full disclosure" about their proffered option not being really useful.
Thanks much for the complete answer to my post. Very illuminating. Apparently the Marine Police officer did the right thing, but now I feel I've wasted a lot of money on the macerator. I fault the Beneteau people for not making "full disclosure" about their proffered option not being really useful.
Macerator isn't useless...
You never leave Mobile Bay. You can use it to dump the tank as long as you're out in the Gulf at least 3 miles from the nearest land. Besides, it shouldn't have cost you more than about $150 installed, so it wasn't that expensive either. There's prob'ly more confusion about marine sanitation laws than any others, especially when it comes to which waters really are "no discharge" and which ones aren't, and what is or isn't a legal treatment device. You might want to get out your organic chemistry textbooks again, btw...'cuz quaternary ammonium compounds are not a "nitrogen rich fertilizer," but a chemical that rivals formaldehyde and gluteraldehyde (the active ingredients in most holding tank chemicals) in environmental UNfriendliness and toxicity. There is a product--Odorlos--in which the active ingredient is nitrates, which eliminates odor by promoting oxygen release from the waste itself, creating the aerobic conditions that prevent odor from occurring, and is a totally environmentally friendly product. However, it can hardly be described as "nitrogen rich fertilizer" either.
You never leave Mobile Bay. You can use it to dump the tank as long as you're out in the Gulf at least 3 miles from the nearest land. Besides, it shouldn't have cost you more than about $150 installed, so it wasn't that expensive either. There's prob'ly more confusion about marine sanitation laws than any others, especially when it comes to which waters really are "no discharge" and which ones aren't, and what is or isn't a legal treatment device. You might want to get out your organic chemistry textbooks again, btw...'cuz quaternary ammonium compounds are not a "nitrogen rich fertilizer," but a chemical that rivals formaldehyde and gluteraldehyde (the active ingredients in most holding tank chemicals) in environmental UNfriendliness and toxicity. There is a product--Odorlos--in which the active ingredient is nitrates, which eliminates odor by promoting oxygen release from the waste itself, creating the aerobic conditions that prevent odor from occurring, and is a totally environmentally friendly product. However, it can hardly be described as "nitrogen rich fertilizer" either.
Knowledge is Power
I have obviously served as foil to Peggie's superior knowledge for which I thank her. My knowledge doesn't include organic chemistry beyond gardening and lawn care, which is why I made the original request for help. The product, Odorlos, that you mentioned is carried by West Marine. The label is apparently where I got the idea about digestion. Now, as an engineer, I do know about the advantages of aerobic (with oxygen) treatment. There are composting heads on the market which both digest and dry the sewage, but these require at least moderate electrical supplies. When will someone do a wet version bubbling air through the holding tank to make a type I MSD? Since drying wouldn't be involved the electrical requirements should be much lower. How much lower needs to be determined in a feasibility study by a competent chemist/en- vironmentalist familiar with the legal effluent limits. Patents, anyone?
I have obviously served as foil to Peggie's superior knowledge for which I thank her. My knowledge doesn't include organic chemistry beyond gardening and lawn care, which is why I made the original request for help. The product, Odorlos, that you mentioned is carried by West Marine. The label is apparently where I got the idea about digestion. Now, as an engineer, I do know about the advantages of aerobic (with oxygen) treatment. There are composting heads on the market which both digest and dry the sewage, but these require at least moderate electrical supplies. When will someone do a wet version bubbling air through the holding tank to make a type I MSD? Since drying wouldn't be involved the electrical requirements should be much lower. How much lower needs to be determined in a feasibility study by a competent chemist/en- vironmentalist familiar with the legal effluent limits. Patents, anyone?
Ooops, sorry...I thought "Dr" Brown meant you're an MD
Don't confuse "treating" waste in a holding tank to eliminate odor with treatment required of Type I and II MSDs, as set forth in the Code of Federal Regulations: The discharge from a Type I MSD must be macerated to the extent that there are no visible solids; in other words, pureed into liquid. The allowable bacteria count must be fewer than 1,000 per 100 mililiter. The discharge from a Type II MSD may not have a bacteria count greater than 200 per 100 mililiter, and suspended solids may not exceed 150 mg./1. Therefore, compost is not treated waste as defined by federal law, and therefore cannot legally be dumped overboard inside the "3 mile limit." Holding tank aeration systems already exist--the Groco Sweetank System is one--but although aeration does assist in breaking down and emulsifying solids and paper (and in fact is used in several Type II systems to both prevent odor and break down solids), aeration doesn't kill bacteria, so how could just aerating a tank turn it into a Type I? There is a system--the Groco ThermoPure--that uses heat to kill bacteria, but its power requirements (and price) are huge. Every other Type I and II except the Lectra/San requires the use of toxic chemicals to kills bacteria. Before you can reinvent the industry, you're gonna have change several federal laws...and someone else--Rept Jim Saxton (R-NJ) is already trying to do that. There's a Bill pending congress--H.R. 1027 was the 2003 version of it...you can read it at http://www.theorator.com/bills108/hr1027.html But first, you prob'ly ought to know what's in the laws he's trying to change. You can read those at: http://www.access.gpo.gov/nara/cfr/waisidx_02/40cfr140_02.html and http://www.access.gpo.gov/nara/cfr/waisidx_03/33cfr159_03.html There are also a whole bunch of CG regs you prob'ly should read too...they're buried in http://www.access.gpo.gov/uscode/title46/subtitleii_partb_chapter43_.html And finally, you prob'ly should familiarize yourself with all the Type I and I devices that already exist (at least all that are sold in the US): The Raritan Lectra/San, PuraSan (Type Is) and ManaGerm (Type II) are at http://www.raritaneng.com The Groco ThermoPure (and Sweetank aerator) are at http://www.groco.net The Microphor Type I and II systems are at http://www.microphor.com HeadHunter Type I and II systems are at http://www.headhunterinc.com/ and Galley Maid Type I and II systems are at http://www.galleymaid.com/sanitation.htm Have fun! However, IMO your time will be more profitably--and far more enjoyably--spent by going sailing instead of plowing through all that stuff.
Don't confuse "treating" waste in a holding tank to eliminate odor with treatment required of Type I and II MSDs, as set forth in the Code of Federal Regulations: The discharge from a Type I MSD must be macerated to the extent that there are no visible solids; in other words, pureed into liquid. The allowable bacteria count must be fewer than 1,000 per 100 mililiter. The discharge from a Type II MSD may not have a bacteria count greater than 200 per 100 mililiter, and suspended solids may not exceed 150 mg./1. Therefore, compost is not treated waste as defined by federal law, and therefore cannot legally be dumped overboard inside the "3 mile limit." Holding tank aeration systems already exist--the Groco Sweetank System is one--but although aeration does assist in breaking down and emulsifying solids and paper (and in fact is used in several Type II systems to both prevent odor and break down solids), aeration doesn't kill bacteria, so how could just aerating a tank turn it into a Type I? There is a system--the Groco ThermoPure--that uses heat to kill bacteria, but its power requirements (and price) are huge. Every other Type I and II except the Lectra/San requires the use of toxic chemicals to kills bacteria. Before you can reinvent the industry, you're gonna have change several federal laws...and someone else--Rept Jim Saxton (R-NJ) is already trying to do that. There's a Bill pending congress--H.R. 1027 was the 2003 version of it...you can read it at http://www.theorator.com/bills108/hr1027.html But first, you prob'ly ought to know what's in the laws he's trying to change. You can read those at: http://www.access.gpo.gov/nara/cfr/waisidx_02/40cfr140_02.html and http://www.access.gpo.gov/nara/cfr/waisidx_03/33cfr159_03.html There are also a whole bunch of CG regs you prob'ly should read too...they're buried in http://www.access.gpo.gov/uscode/title46/subtitleii_partb_chapter43_.html And finally, you prob'ly should familiarize yourself with all the Type I and I devices that already exist (at least all that are sold in the US): The Raritan Lectra/San, PuraSan (Type Is) and ManaGerm (Type II) are at http://www.raritaneng.com The Groco ThermoPure (and Sweetank aerator) are at http://www.groco.net The Microphor Type I and II systems are at http://www.microphor.com HeadHunter Type I and II systems are at http://www.headhunterinc.com/ and Galley Maid Type I and II systems are at http://www.galleymaid.com/sanitation.htm Have fun! However, IMO your time will be more profitably--and far more enjoyably--spent by going sailing instead of plowing through all that stuff.
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