COMMON QUESTIONS ABOUT VERMONT'S AST REGULATIONS
Does piping on an old tank need to be removed?
Under the Vermont AST Rules, effective August 1, 2024, piping removal is addressed explicitly in Section 9-306 (Proper Removal of Tank Systems). The rules state that any aboveground storage tank system that has been out of service for more than 1 year must be removed, including all associated piping. For tanks located inside a structure, the fill pipe must be fully and permanently removed from the structure to prevent any future delivery to a disconnected system. In addition, the rules are clear that if a structure converts to a different heating fuel and is no longer served by the AST system, the tank system and any fill pipes must be removed at the same time as the fuel conversion. For clarity, the AST Rules define “out-of-service” as a condition in which a tank system is disconnected from a heating source or distribution system or is otherwise not in use.
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Do all fuel lines between the tank and the burner need to be coated AND sleeved?
If this is a new installation (installed after August 1, 2024) and the fuel line is in contact with concrete or “earthen materials,” the answer is yes. However, if it is an existing tank system (installed before August 1, 2024) with above-ground (non-buried) fuel lines and lines that are not in contact with concrete or dirt, the answer is no.
All new installations where fuel lines are in direct contact with concrete or earthen materials, such as dirt or gravel, must be protected from corrosion. Therefore, all underground fuel lines installed through concrete floors or walls, or directly on concrete or dirt floors, must have a plastic coating; there are no exceptions to this requirement for new installations. For existing systems (installed before August 2024), the current fuel line corrosion protection requirement applies only to tanks with fuel lines installed below grade (through a concrete floor or buried). Starting in July 2030, existing systems must comply with the same corrosion protection requirements as new systems. However, until 2030, existing tank systems with above-grade fuel lines (such as those directly on top of concrete floors) are considered compliant even if the fuel lines are not coated in plastic.
Similar to the requirements for fuel line corrosion protection, new installations where fuel lines are in contact with concrete or earthen materials must be protected from physical damage. DEC implemented this new requirement in 2024 to reduce the risk of releases from fuel lines damaged by foot traffic or by heavy objects placed or dropped on them. In one recent example, workers cleaning out a flooded basement trampled and damaged an unprotected fuel line, causing a 220-gallon fuel spill. To meet this requirement, fuel lines installed directly on concrete or dirt flooring should be sleeved in crush-resistant conduit. Vermont’s AST Regulations do not prescribe a specific sleeving material that must be used to meet this requirement. The professional judgement of tank installers to determine which material is most appropriate. DEC also waives the sleeving requirement for fuel lines installed immediately against walls, where the risk of physical damage is low because they are not installed in foot-traffic areas. Similar to the corrosion protection requirements, existing tank systems are not subject to the sleeving requirement until July 1, 2030.
In November 2024, the DEC developed a guidance document on this topic, you can find it here. Always feel free to call DEC if you need help understanding the requirements or want to discuss a particular installation. DEC will also update inspection checklists to clarify the sleeving requirement for new installations. Any inspection checklist published after August 2024 may be used for tank inspections, so the newer, updated checklist is encouraged but not required. All DEC checklists are posted here.
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Does the entire tank have to come into the latest standards if one part of the tank system is changed?
If an existing tank system was designated as noncompliant for a particular component, then only that identified noncompliant component must be repaired/replaced/upgraded to remove the red or yellow tag. For example, if an existing tank is yellow or red tagged for not having a functional vent alarm, but the tank also has above-grade nonprotected fuel lines and is not installed on a continuous solid foundation, only the vent alarm issue must be resolved to remove the red/yellow tag.The remaining two items (coating/sleeving of fuel lines and concrete pad foundation) do not become required compliance items for existing tanks until July 1, 2030, and the Agency does not require that those upgrades take place at the same time as the vent alarm repair/upgrade. The only exception to this rule is if the AST system fails an inspection due to rust or leaking of the tank and the tank must be replaced. In such case, the Agency will consider the entire AST system a “new installation” and therefore, all components must be in compliance with every standards set in the rules for new tanks (including having coated/sleeved fuel lines, placed on a solid foundation, tank not less than 12-gauge in thickness or double-wall, tank has fuel gauge, if tank located in flood prone area it is anchored to foundation, etc.).
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When do I use a yellow tag?
Yellow tags are only approved for use with tanks installed BEFORE 8/1/24. Any tank installed after 8/1/24 must be installed in full compliance with all standards set in the rules, including the coated/sleeved fuel line requirement to protect fuel lines from corrosion and damage and the flood-prone area tank anchoring requirements. If a new tank is installed only in partial compliance with rules, the tank should be red tagged and no fuel should be delivered until noncompliant (or missing) tank components are upgraded or installed. Always use the new installation/first fill checklist before you make the first fuel delivery to a newly installed AST system to ensure that the tank was installed correctly and in compliance with all the rules, especially if a third party installed the tank. If any of the responses on this checklist are “no”- do not fill the tank until corrections are made.
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Can I fill a two tank system with a manifold?
Section 9-303-11 on page 15 says "Any aboveground storage tank system that includes more than one storage tank shall have, for each individual tank, a separate fill pipe, a separate fuel volume gauge, a separate vent pipe, and a separate vent alarm, each of which comply with the requirements of this section. The separate vents may be plumbed or manifolded together inside the building and tied into one outlet vent pipe that goes to the outside of the structure, provided that the outlet pipe is at least one pipe size larger than the largest individual vent pipe connected thereto; and the point of connection between two or more vent pipes shall not be lower than the top of the fill pipe opening on the tank." More here.
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