LECTRA/SAN Type I MSD
Al Gunther
My boat plans call for a LECTRA/SAN Type I MSD waste treatment unit.
While Type I's are presently legal in most areas, I understand I will
have to lock it shut to go into "no discharge" areas.
What's the speculation on how far the "no discharge" areas will extend
in years to come? How big a deal is it to go into a "no discharge" area
and have to "lock up"? I'm assuming if this is a marina and I want to
spend the night, I just use the public restrooms.
The designer left me enough room for a holding tank where the MSD goes,
so backfitting at a later date wouldn't be too bad if I decide I need
to. Backfitting, however, wouldn't be a happy choice. BTW, this is a
small cruising sloop, not a liveaboard.
Any experiences or advice?
Al in Kingston, WA
David Zielke
> While Type I's are presently legal in most areas, I understand I will
> have to lock it shut to go into "no discharge" areas.
This is correct.
> What's the speculation on how far the "no discharge" areas will extend
> in years to come? How big a deal is it to go into a "no discharge" area
> and have to "lock up"? I'm assuming if this is a marina and I want to
> spend the night, I just use the public restrooms.
I think that this depends on how reasonable people become. The problem
is that people will use their LECTRA/SAN while in low flow rate areas, i.e.,
marinas and small anchorages. The local population gets fed up with it and
complains and once they can get it passed the area will become no discharge.
Others would argue that the LECTRA/SAN really does little more good than
a macerator (SP?). The problem in many areas is not as much the biological
contamination from human waste but rather the addition of organic material
to a small ecosystem. For example, here on the Cheasapeake Bay many would
argue that one of the biggest problems are all of the dairy farms in PA
which add a lot of fertilizer and other organic matter to the water.
Compound that with adding human organic material to an area which may not
get flushed out very well and you have the potential for trouble.
> The designer left me enough room for a holding tank where the MSD goes,
> so backfitting at a later date wouldn't be too bad if I decide I need
> to. Backfitting, however, wouldn't be a happy choice. BTW, this is a
> small cruising sloop, not a liveaboard.
Personally, I would install a high quality holding tank of the largest
size practicle. Use the highest quality hose and tank you can obtain and
use one of the holding tank deoderizers (biological or chemical) and the
difficulties are minimized. I have been doing this for several years as a
liveaboard and it has worked very well.
Terry Steinford
your boat if it is less than 65 feet LOA. The CG regulations say that
only a type II could be installed after January 30, 1980, but they
published a waiver in the Federal Register on July 10, 1978. The
waiver says that a type I certified MSD can be installed or replaced
on any boat less than 65 feet. The regulations have never been
changed, but the waiver is still in force.
No discharge areas are only approved by the U.S. EPA after a state
government applies for a no discharge designation and proves that
sufficient pump out stations have been installed. The entire states
of Michigan and New Mexico have been designated. Portions of 12 other
states have also been designated, ranging from most of the state to
only one harbor.
Crusing World magazine had a very good article in April 94, which
gave the legal details and several practical designs for actual
installations.
The article lists the no discharges area for California as: Avalon Bay,
Channel Islands at Oxnard, Dana Point, Hunington, Mission Bay, Newport
Bay, Oceanside Richardson Bay, San Diego Bay, St. Catalina island, Sunset
Bay, Lake Tahoe. None are listed for Washington or Oregon.
Holding tanks do not need to be CG certified. As long as the tank
only holds sewage at ambient pressure and temperature, there is no
certification or labeling required.
If you are installing a treatment system/holding tank combination,
don't forget to locate the overboard discharge valve where you can
get to it easily because you are required to lock or tie it shut when
in a no discharge area.
--
Terry Steinford
t...@gate.net
Scott Williams
> You can install a Coast Guard certified type I treatment system in
> your boat if it is less than 65 feet LOA. The CG regulations say that
> only a type II could be installed after January 30, 1980, but they
> published a waiver in the Federal Register on July 10, 1978. The
> waiver says that a type I certified MSD can be installed or replaced
> on any boat less than 65 feet. The regulations have never been
> changed, but the waiver is still in force.
>
> No discharge areas are only approved by the U.S. EPA after a state
> government applies for a no discharge designation and proves that
> sufficient pump out stations have been installed. The entire states
> of Michigan and New Mexico have been designated. Portions of 12 other
> states have also been designated, ranging from most of the state to
> only one harbor.
Terry, did Florida get EPA approval for its no discharge law? If so,
their idea of sufficient pump out stations leaves much to be desired.
If not, EPA approval is not necessary for entire states to pass
no-discharge laws. In fact, does a state need federal aproval of laws
which affect state waters?
-Scott (here we go again)
Terry Steinford
: Terry, did Florida get EPA approval for its no discharge law? If so,
: If not, EPA approval is not necessary for entire states to pass
: no-discharge laws. In fact, does a state need federal aproval of laws
: which affect state waters?
The Florida law passed last year established a no discharge standard
only for houseboats. It did not make the state 'no discharge' for any
other type of vessel. No EPA designation or review is required for
any state to establish a more stringent standard only for houseboats.
The federal law on this subject is the Federal Water Pollution
Control Act (33 USC 1322(f) which reads:
"(f)(1)
(A) Except as provided in subparagraph (B), after the effective
date of the initial standards and regulations promulgated under this
section, no State or political subdivision thereof shall adopt or
enforce any statute or regulation of such state or political
subdivision with respect to the design, manufacture, or installation
or use of any marine sanitation device on any vessel subject to the
provisions of this section.
(B) A State may adopt and enforce a statute or regulation with
respect to the design, manufacture, or installation or use of any
marine sanitation device on a house boat, if such statute or
regualtion is more stringent than the standards and regulations
promulgated under this section. For purposes of this paragraph, the
term "houseboat" means a vessel which, for a period of time
determined by the State in which the vessel is located, is used
primarily as a residence and is not used primarily as a means of
transportation."
[paragraphs (2), (3), and (4) detail how US EPA handles an
application from a state for a no discharge area designation for
vessels other than houseboats.]
Paragraph (1)(B) was added by the Water Quality Act of 1987.
Under the Florida law houseboats that already have certified type I
or II treatment systems installed do not have to install a no
discharge system until October 1, 1996.
The general rule on state and federal jurisdiction is that both can pass
and enforce laws on the same subject unless the U.S. Congress passes a law
that asserts a federal premption, or the U.S. Constitution reserves the
subject to the federal government. The first paragraph of the above law is
such a preemption. As originally passed, the entire subject of toilets on
boast was reserved to the federal government. The revision in the second
paragraph gave back a portion of the subject to the states.
Since the subject of toilets on boats is not one of the specifically
enumerated federal powers in the U.S. Constitution, laws like this hang
their hat on the interstate commerce clause. Depending on which way the
wind blows in the courts, it might not survive a challenge. On the other
hand there is some advantage to having some uniformity nationwide.
-- Terry Steinford
t...@gate.net