The update deadline for your Stormwater Pollution Prevention Plan or SWPPP is fast approaching! In this post we will go over what need to know for updating your SWPPP to be in compliance for the new permit.
SWPPP Update Deadline: May 15, 2025
*Note: While your SWPPP must be up to date and available onsite by May 15th, you will not need to submit your updated SWPPP online or elsewhere unless specifically requested by Ecology to do so.
Read all SWPPP requirements in the 2025 ISGP
Quickly Identify New Changes in the 2025 ISGP Redline
SWPPP Template Update
Ecology has updated the SWPPP template to meet the current permit requirements. This template is a great tool to identify new areas you need to add to your SWPPP and for facilities that are building a SWPPP from scratch. While you aren’t required to use the SWPPP template, it can be a valuable reference for all facilities under the ISGP
ISGP SWPPP Template Final 2025
Updates to site maps

One of the biggest changes to the SWPPP is regarding site maps. There are 4 new items you will need to identify on your site maps. Given the sheer number of items identified in the site map, most facilities have multiple pages to allow things to be clearly identified.
New items you must identify on your site map:
- Areas where equipment cleaning is conducted
- Locations where vehicles are parked or stored
- Areas where industrial activity is conducted
- Locations of groundwater discharge points
New Tire Covering BMPs

The 2025 permit requires that permittees “Keep all used and new tires under cover or stored in a storm-resistant shelter”. Your tire coverings need to be identified in the SWPPP along with your other Good Housekeeping practices.
BMP Maintenance Log

Your SWPPP needs to outline BMPs related to preventative maintenance, and the 2025 ISGP now requires a BMP maintenance log to record each maintenance task. The permit specifies that while the BMP maintenance log does not need to be maintained with the SWPPP, it but be available upon request by ecology or local jurisdictions.
Training Plan/ Training Log

Your SWPPP needs to include a training plan to train your employees as well as contractors and vendors who have duties in areas of industrial activity and the potential to impact stormwater quality. The vendor and contractor aspect of this training is new to the 2025 permit. Your SWPPP should also contain a log of the employees, contractors, and vendors who have completed training, including training date.
Illicit Discharge/ Illicit Connections

Your SWPPP needs to include the methodologies you will use to identify and eliminate Illicit Discharges and Illicit Connections. New to the 2025 ISGP is the explicit requirement to identify and eliminate illicit connections. Also new to the 2025 permit is the inclusion that process wastewater shouldn’t be allowed to discharge to ground.
Sampling Plan

Some facilities may need to update their sampling plan to meet the new sampling requirements. Sites that may need to update their sampling plan include facilities that:
- Have new sampling requirements for PFAS
- Have and expanded facility footprint due to the new definition of area of industrial activity
- Have new sampling requirements for discharge to ground resulting from PFAS sampling requirement or a functionally equivalent discharge to surface water
- Are making a required transition from pH test strips to a calibrated pH meter as required under the 2025 permit.
Spill Prevention and Emergency Cleanup Plan
Facilities should check that the Spill Prevention and Emergency Cleanup Plan (SPECP) is up to date and compliant with the 2025 permit requirements. New Changes include:
- Secondary Containment Calculations: Note that stormwater conveyance systems cannot be used as part of the secondary containment calculation. If your current SWPPP uses this in the calculation, you may need to edit this section of your SWPPP and upgrade your secondary containment on site.
- Containment Area Valves: The 2025 permit requires that containment areas with a valve need to keep valve closed until verification that no visible oil sheen is present prior to opening the discharge valve. This procedure may need to be included within your SWPPP if this scenario applies.
Other SWPPP Requirements
The list above is just a highlight of new items that may need to be included in your SWPPP and is not inclusive of everything to include within your SWPPP. I would encourage you to read the permit and checkout the updated ISGP SWPPP Template for a more inclusive overview of SWPPP requirements.
For questions on SWPPP Updates or other ISGP permit assistance, contact Brandon Boyd via email: [email protected]
