ISGP: Make a Plan

Your Stormwater Pollution Prevention Plan (SWPPP) describes what you are doing, how you will do it, and what BMPs you are going to implement to maintain permit compliance at all your discharge points. Each permitted project must submit a Stormwater Pollution Prevention Plan (SWPPP); outlined in Section S3 of the ISGP.

The SWPPP outlines what the project compliance expectations are and what tools and techniques the site will implement to achieve those outcomes. Ecology has created a SWPPP template that can be used to generate the necessary information. It is not required to utilize this template but it does act as a guide to what is necessary to include.

Your SWPPP

The SWPPP is a “living document” and will change over time. It is critical to make sure that SWPPP changes are made as adaptive management of stormwater changes or personnel and/or operations changes over time.

What is a SWPPP?

SWPPP is the detailed plan that describes what industrial activity occurs on the site; where the industrial activity occurs; when and how the industrial activity occurs and who is managing the stormwater protection at the facility. After describing everything about the industrial activity, you will identify all the BMPs that are being utilized to prevent stormwater pollution from those activities.

Who Creates the SWPPP?

It is expected that the SWPPP is developed by “qualified personnel” which refers to a person who is knowledgeable about stormwater and the site. The is responsible for ensuring that the facility implements all the BMP tools available that are feasible for the site, defined as AKART (all known, available, reasonable methods of prevention, control, and treatment), and that those referenced in the most current version of the Eastern Washington or Western Washington Stormwater Management Manual respectively, or at minimum have demonstrably equivalent capabilities as a BMP identified in the manual.

SWPPP Component: Title Page

The title page of the SWPPP should identify all necessary information on site location, site name, owner/operator, qualified person(s), permit number, receiving water, and other information such as identified participants in the stormwater program on-site. This is essentially the one-page stat sheet of the SWPPP and gives you the critical information on one page.

What to Include on a SWPPP Title Page

Site Name
Site Address
Site Phone Number
Site Operator Name
Site Operator Phone Number
Site Operator Email
SWPPP Creation Date

SWPPP Component: BMPs

A major component of the SWPPP is outlining the Best Management Practices (BMPs) you will be implementing on your site. BMPs are….There are certain BMPs required at all sites, some BMPs that are facility-specific, and even more optional BMPs that can be utilized to avoid exceeding water quality benchmarks set by the permit.

To learn more about BMPs and to see examples, please see our Industrial BMP page

SWPPP Component: Site Maps

The site map is one of the most critical elements of any stormwater program. Without having 100% confidence in how stormwater moves both at the surface and in the subgrade of the facility, BMP decisions become more “guessing” and “hope” than focused decision-making. The site map(s) must include over 15 pieces of information and often requires more than one map to achieve. The site map should mirror the narrative in the site description of the SWPPP so that the reader can identify what is being discussed in the SWPPP while looking at the site map.

Creating a Site Map

Many site maps rely on CAD-drawn, as-built maps, however, depending on when the maps were generated, often the stormwater drainage system can be changed over time and it becomes important to make sure if the as-builts are not available that discovery is completed on the site to determine the flow of the system. Site maps can be developed by utilizing market-available platforms such as Google Earth as a base layer and drawing over the top with programs such as PowerPoint, Visio, SmartDraw, or a variety of other software programs that are easy to use.

SWPPP Component: Spill Prevention and Emergency Cleanup Plan

Your SWPPP must include a SPECP that outlines the BMPs you will use to prevent spills that can contaminate stormwater. This should also include information about the type, location, and contents of spill kits throughout the site, as well as any employee training and tracking needed to ensure spill response readiness. This document should be able to stand alone apart from the SWPPP to be utilized as a tool by site staff.

ISGP Requirements for an SPECP Compliant Spill Kit

Locate spill kits within 25 feet of all stationary fueling stations, fuel transfer stations, mobile fueling units, and used oil storage/transfer stations. At a minimum, spill kits shall include:

i) Oil absorbents capable of absorbing 15 gallons of fuel. Facilities with a Spill Prevention, Control, and Countermeasures Plan (SPCCP) must have enough oil absorbents capable of absorbing the minimum anticipated spill amount or potential discharge volume identified in that plan if more than 15 gallons.

ii) A storm drain plug or cover kit.

iii) A non-water containment boom, a minimum of 10 feet in length with a 12-gallon absorbent capacity.

iv) A non-metallic shovel.

v) Two 5-gallon buckets with lids.

Site-Specific Requirements

The US EPA requires some sites also have an SPCC (Spill Prevention, Control, and Countermeasures) plan due to the volume of hydrocarbon-based materials stored or utilized on site. That SPCC in many cases can suffice as the SPECP, but it is important to note that the ISGP SPECP does not just focus on hydrocarbon-based material and requires very specific elements be met that may or may not be included in the SPCC – so it is important to verify that first. For more information see the EPA’s SPCC Guide or SPCC Template.

SWPPP Component: Sampling Plan

Like the SPECP, the Sampling Plan is not only a required element of the SWPPP but also can act as a good stand-alone document. That way if the qualified person is not available or ceases to work for the company, there are instructions on how to collect samples appropriately for another trained person or for a successor taking over that position. The sample plan should identify where samples are collected; what is being sampled for at each location; sample collection procedures; the laboratory sample handling procedures; chain of custody, labeling, and other recordkeeping instructions; and a sample log to be filled out for each sampling event. Review the Monitoring page to get more details on what goes into a Sampling Plan.

7 Components of a Sampling Plan

Identify all discharge locations
Identify all sampling locations with a unique ID
Identify any substantially identical outfalls
Identify Staff responsible for sampling
Specify sample collection and Handling procedures
Specify procedures for reporting results to Ecology (DMRs)
Identify sampling parameters and their holding procedures and analytical methods

SWPPP Component: Education Program

Employee education must be conducted annually at a minimum, and any time new staff that will be managing or responsible for stormwater are hired. The Employee Education Program needs to be outlined in the SWPPP. There are commercially available training programs available, but it is always important to supplement those programs with site-specific knowledge of spill control and stormwater flow and BMPs

What to Include in Your Training Program

An overview of what is in the SWPPP.
How employees make a difference in complying with the SWPPP and preventing contamination of stormwater.
Spill response procedures, good housekeeping, maintenance requirements, and material management practices.

Other Considerations

SWPPP Certification

Any time a new SWPPP is created or an existing SWPPP is modified, someone with signing authority for the site must complete a new SWPPP Certification form.

Maintenance Logs

Keeping a maintenance log of BMP maintenance such as sweeping, system cleaning, filter changeouts, media placement, etc is very important in completing the Annual Report and in tracking budgetary costs. Some of these maintenance-type BMPs are mandated by the permit and it is important to have them on record.

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