FAILURE TO ISSUE OR REISSUE DISCHARGE AUTHORIZATION ORDERS. FAILURE TO DEVELOP, IMPLEMENT, AND ENFORCE PRETREATMENT STANDARDS AND LIMITS AS REQUIRED BY THE DOCUMENT ENTITLED INDUSTRIAL PRETREATMENT PROGRAM, AUGUST 2, 1985 AND CPDS PERMIT NO. CO-0039641. FAILURE TO DEVELOP AND ENFORCE LIMITS AS REQUIRED UNDER 40 CFR 403.5(C) TO IMPLEMENT THE PROHIBITIONS AGAINST PASS THROUGH AND INTERFERENCE AS PROVIDED FOR AT 40 CFR 403.5(A). FAILURE TO IMPLEMENT ITS PRETREATMENT PROGRAM, DELTA HAS VIOLATED ITS DISCHARGE PERMIT FOR BOD AND TOTAL SUSPENDED SOLIDS CONTINUOUSLY SINCE DECEMBE 1988.