FAILURE TO PROPERLY IMPLEMENT ITS PRETREATMENT PRO- GRAM AS (1) FAILURE TO ISSUE OR REISSUE INDUSTRIAL USER PERMITS FOR SIGNIFICANT INDUSTRIAL USERS WITHIN SIX MONTHS AFTER ITS PROGRAM APPROVAL, AND (2) FAILLURE TO DEVELOP, IMPLEMENT, AND ENFORCE PRETREATMENT STANDARDS (INCLUDING CATEGORICAL STANDARDS AND LOCAL LIMITS) IN AN APPROVED PROGRAM AND NPDES PERMIT.