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SWPPP Updates for 2025 ISGP

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

example sitemap from satellite imagery of wsu-puy campus

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
Full Site Map list
a) The scale or include relative distances between significant structures and drainage systems.

b) The size of the property in acres.

c) The location and extent of all buildings, structures and all impervious surfaces.

d) Direction of stormwater flow (use arrows).

e) Locations of all structural source control BMPs.

f) Locations of all receiving water (including wetlands and drainage ditches)waters in the immediate vicinity of the facility.

g) Conditionally approved non-stormwater discharges.

h) Areas of existing and potential soil erosion that could result in the discharge of a significant amount of turbidity, sediment, or other pollutants.

i) Locations of all stormwater conveyances including ditches, pipes, catch basins, vaults, ponds, swales, UICs, etc.

j) Locations of actual and potential pollutant sources.

k) Locations of all stormwater monitoring points.

l) The approximate contributing stormwater drainage areas for each stormwater discharge point off site (including discharges to groundwater).

m) Locations of stormwater inlets and outfalls with a unique identification number for each sampling point and discharge point, indicating any that are identified as substantially identical, and identify, by name, any other party other than the Permittee that owns any stormwater drainage or discharge structures.

n) Combined sewers or MS4s and where stormwater discharges to them.

o) Locations of fueling and vehicle maintenance areas, and areas where equipment cleaning is conducted.

p) Locations where vehicles are parked or stored.

q) Areas where industrial activity is conducted.

r) Locations and sources of run-on to the site from adjacent properties that may contain pollutants.

s) Locations of groundwater discharge points.

New Tire Covering BMPs

Cinderblock and metal covering with Tires and a dumpster stored inside
Photo Courtesy of Washington Dept of Ecology

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.

Other Good Housekeeping BMPs to include
a) Vacuum paved surfaces with a vacuum sweeper (or a sweeper with a vacuum attachment) to remove accumulated pollutants a minimum of once per quarter.

b) Identify and control all on-site sources of dust to minimize stormwater contamination from the deposition of dust on areas exposed to precipitation.

c) Inspect and maintain bag houses monthly to prevent the escape of dust from the system. Immediately remove any accumulated dust at the base of exterior bag houses.

d) Keep all dumpsters under cover or fit with a storm- resistant lid that must remain closed when not in use in order to prevent the contamination of stormwater or release of leachate.

e) Keep all used and new tires under cover or stored in a storm-resistant shelter.

BMP Maintenance Log

worker in high viz vest cleaning out catchbasin using vaccuum truck

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.

BMP Maintenance Items to Log
a) Clean catch basins when the depth of debris reaches 60% of the sump depth. In addition, the Permittee must keep the debris surface at least 6 inches below the outlet pipe.

b) Maintain ponds, tanks/vaults, catch basins, swales, filters, oil/water separators, drains, and other stormwater drainage/treatment facilities in accordance with the maintenance standards set forth in the applicable Stormwater Management Manual, other guidance documents or manuals approved in accordance with S3.A.3.c, demonstrably equivalent BMPs per S3.A.2.d, or an O&M Manual submitted to Ecology in accordance with S8.D.

c) Inspect all equipment and vehicles during monthly site inspections for leaking fluids such as oil, antifreeze, etc. Take leaking equipment and vehicles out of service or prevent leaks from spilling on the

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

man inspecting stormwater drainage pipes

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

water flowing from outlet pipe into sample bottle

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.
Read More about the Spill Prevention Emergency Cleanup Plan
From the permit: ” Spill Prevention and Emergency Cleanup Plan (SPECP): The SWPPP shall include a SPECP that includes BMPs to prevent spills that can contaminate stormwater. The SPECP shall specify BMPs for material handling procedures, storage requirements, cleanup equipment and procedures, and spill logs, as appropriate. The Permittee shall:

a) Store all hazardous substances, petroleum/oil liquids, and other chemical solid or liquid materials that have potential to contaminate stormwater on an impervious surface that is surrounded with a containment berm or dike that is capable of containing 10% of the total enclosed tank volume or 110% of the volume contained in the largest tank, whichever is greater, or use double-walled tanks. Stormwater conveyance systems cannot be used as part of the secondary containment calculation.

b) Prevent precipitation from accumulating in containment areas with a roof or equivalent structure or include a plan on how it will manage and dispose of accumulated water if a containment area cover is not practical. If the containment area has a valve, it is to remain closed until verification that no visible oil sheen is present prior to opening the discharge valve.

c) 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 shovel.

     v) Two 5-gallon buckets with lids or equivalent inert receptacles.

d) Assure that fueling nozzles are not locked in the open position. Do not “top-off” tanks being refueled.

e) Block, plug or cover storm drains that receive runoff from areas where fueling or maintenance occurs, during fueling or vehicle fluid changes. Facilities with secondary containment around fueling areas must keep the containment area discharge valve closed during fueling.

f) Use drip pans or equivalent containment measures during all petroleum transfer operations.

g) Locate materials, equipment, and activities so that leaks are contained in existing containment and diversion systems (confine the storage of leaky or leak-prone vehicles and equipment awaiting maintenance to protected areas).

h) Use drip pans or other effective measures below leaking vehicles (including inoperative vehicles and equipment) in a manner that catches leaks or spills. Drip pans or other effective containment methods must be managed to prevent overfilling and the contents disposed of properly. Absorbent materials must be managed to prevent impacts to stormwater runoff during storm events. Drain fluids from equipment and vehicles prior to on- site storage or disposal if feasible.

i) Maintain a spill log that includes the following information for chemical and petroleum spills: date, time, amount, location, and reason for spill; date/time cleanup completed, notifications made and staff involved.”

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]