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proceedings that challenge the issuance of cnforcentettt action, as contrasted with proceedings that object to the "modificarioo, vacation, or termination" of enforcement action. Ifte statute allows either the "operator" to whom DMG issues enforocutent action or any "person having an interest which is or may be adversely affected by" such action to reyuest administrative review. In contrast the statute allows only a "person having an interest which is or may be adversely affected by" an existing enforcement action to challenge its '~nodificalion, vacation, nr termination." The narrower standing provision for challenges to modifications, vacations, or terminations unmistakably marks such proceedings as separate and distinct from challenges to the issuance of enforcement action, which operators may bring without first establishing injury to interest. More importantly, each proceeding ruiscs separate and distinct legal issues. .4 proceedinS to challenge the issuance of enforcement action toms on (1) whether the operator has violated the law and (2) whether DMG has required appropriate remedial measures or provided sullicietrt time tv accomplish them. In markeil contrast, a proceeding to challenge "modification, vacation, or termination" of enforcement action assumes that a violation has occurred and that DMG appropriately addressed that violation initially. "the focus of such separate proceedings is whether DMG has abused its discretion in modifying the required remedial action or timetable or in concluding the enforcement effort altogether. Accordingly, despite Basin's insistence to the contrary, the Boazd order at issue here is "final agency action" on the company's objection to vacation ol~thc NOV rather than an intermediate step in prviceedings iv determine whether DMG properly issued the NOV itt the first place. Even if the -]0-