MEMORANDUM OPINION
PHILLIPS, District Judge.
Plaintiff, Pryor Oil Co., Inc., has requested judicial review of an administrative order, issued by the Environmental Protection Agency (EPA), pursuant to § 311(c) of the Clean Water Act, 33 U.S.C. § 1321, et seq. The administrative order required plaintiff to take actions in response to an initial discharge and subsequent threat of a discharge of oil to navigable waters and adjoining shorelines...
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