Hmm. That'd be pretty nasty to be on the receiving end of (and may well have been an outrageous abuse of executive power), but still, an administrative freeze is temporary and is not in itself a clawback. Even if it was a certainty this would happen to PSF, it would still be worth it for $1.5 million!

It was not temporary. The victims spent substantial amounts of money suing and still lost: https://www.eenews.net/articles/appeals-court-says-epa-can-r.... Technically litigation is ongoing but there is no reason to believe they will succeed.