United States Environmental Protection Agency Region V ("Region") and Lazarus, Inc. ("Lazarus") appeal from an initial decision in which an EPA administrative law judge ("Presiding Officer") assessed a penalty against Lazarus for a variety of violations of EPA's regulations on polychlorinated biphenyls ("PCBs"). The Presiding Officer also dismissed certain counts of the Region's complaint based on the "public protection" provision of the Paperwork Reduction Act ("PRA"), 44 U.S.C. § 3512, and the statute of limitations at 28 U.S.C. § 2462.