Can a Circle K franchisee meet the requirements for environmental pollution/impairment coverage for underground storage tanks by participating in a specific program?

According to Circle K's 2025 Franchise Disclosure Document, franchisees can meet the environmental pollution/impairment coverage requirements for underground storage tanks through specific programs. Franchisees have the option to participate in the federal Environmental Protection Agency (EPA) approved state financial assurance fund. Alternatively, they can use another EPA-approved method to demonstrate financial responsibility. A third option is satisfying any of the other financial assurance test requirements outlined in the EPA's Financial Responsibility Regulations (40 CFR Part 280).

Circle K requires franchisees to maintain environmental pollution/impairment insurance coverage of at least $1,000,000. This coverage must be continuous and uninterrupted, protecting the franchisee from all environmental liabilities related to the storage, handling, dispensing, and/or sale of motor fuel products and lubricants at the store premises, as well as the ownership and operation of the business.

This environmental/pollution impairment coverage must extend for at least two years beyond the expiration, termination, or nonrenewal of the Branding Agreement or Motor Fuel Agreement. This ensures that potential environmental liabilities discovered after the franchise relationship ends are still covered. By offering multiple avenues for meeting the environmental coverage requirements, Circle K provides franchisees with flexibility in choosing the option that best suits their circumstances and complies with EPA regulations.