A local pretreatment program must have four major building blocks in order to succeed. First, the POTW must have the legal authority to implement the program. This legal authority usually is based on state law and local ordinances.
State law authorizes the municipality to regulate industrial users of municipal sewage systems.
The municipality, in turn, establishes a local ordinance that sets forth the components of its pretreatment program and identifies a person empowered to implement the program. It must be authorized to enforce national pretreatment standards and to implement local limits in addition to or in excess of the federal standards. It also must be empowered to issue permits to industrial users, which set forth all applicable pollution control requirements. Finally, the POTW's legal authority must include the right to inspect and monitor industrial facilities without prior notice, and to take enforcement action against violators. In addition to obtaining legal authority, the POTW must develop a comprehensive database describing its industrial discharges.