357 North Main Street
Memphis, TN 38103

Environmental Compliance Audit

Internal Audit of Environmental Permitting, Recordkeeping and Reporting Requirements


Kruger Products' Memphis facility, KTG USA, is the largest manufacturing facility under one roof in the Memphis area. KTG USA is part of Kruger Products L.P., one of North America’s leading manufacturers of quality tissue products for home, industrial and commercial use.

After partnering with Tioga to complete applications for a new tissue machine and a renewal of its Title V Air Permit, KTG USA asked Tioga to be a part of its annual semi-internal environmental audit. Along with another consultant from the northeast, Tioga spent three days touring the facility and poring through records to evaluate compliance with applicable environmental regulations. With two auditors on the project, we decided to divide and conquer, and Tioga reviewed the following regulatory areas:

  • Air Pollution
  • Spill Prevention Control and Countermeasure (SPCC) Plan
  • Stormwater and Stormwater Pollution Prevention Plan (SWPPP)

The audit findings were presented in a table format, consistent with facility corporate standards, which listed the program area, requirement and finding/observation, and identified necessary corrective actions.

After completing the audit, KTG hired Tioga to provide the needed updates for both the SPCC and SWPPP Plans.

To update the SPCC Plan, Tioga performed a site inspection of the facility, conducted interviews, discussed current procedures, and examined all physical structures related to compliance with oil storage requirements under the U.S. EPA oil pollution regulations. Tioga then prepared an updated plan complete with a current inventory of oil storage and accurate inspection forms.

The updated SWPPP was needed to comply with a new Stormwater General Permit that had recently been issued by the State of Tennessee. Tioga prepared the new Notice of Intent for coverage and prepared the updated plan consistent with the new permit. The plan contained a list of exposed materials and potential pollutant sources, identified the pollution prevention team, and described management controls and measures to ensure compliance with regulatory limits for pollutant discharges.