- Admitted to PA, NJ and DC State Bars. Also admitted to the U.S. District Court for the Eastern District of Pennsylvania and the U.S. Court of Appeals for the District of Columbia Circuit.
- Member, Delaware Valley Green Building Council
- Member, Society of Women Environmental Professionals
- Member, Forum of Executive Women
- George Washington University, National Law Center, Washington, D.C., J.D., 1988
- B.A., Environmental Law, University of Pennsylvania, Philadelphia, PA, 1985
Fields of Competence
- Regulatory compliance, including the development and implementation of environmental regulatory compliance programs.
- Negotiations with regulatory agencies, with experience in both civil and criminal environmental enforcement.
- Interpretation of federal environmental laws, including Superfund, RCRA, TSCA, Clean Air Act, Clean Water Act, FIFRA, and SDWA.
- PCB transformer and TSCA compliance projects.
- Brownfield site reuse/redevelopment projects.
- Due diligence and investigations associated with property transactions.
- Clean Air Act and NESHAPs asbestos compliance issues.
- Energy conservation and “LEEDS” considerations as related to project site selection and building construction.
Sarah Keating is the Principal Owner and Chief Executive Officer of Keating Environmental Management, a consulting company which provides comprehensive environmental services to its clients (both public and private sector) including engineering, geology, hydrogeology, asbestos, indoor air quality, health and safety, construction, regulatory compliance, and risk management services. In this capacity, she directly oversees and manages all aspects of the business including financial, business development and marketing, proposal preparation, human resources, risk management and project performance.
Sarah has over 15 years of experience as legal counsel within Region III of the United States Environmental Protection Agency. She served as Assistant Regional Counsel for 11 years and as Senior Regional Criminal Enforcement Counsel for 4 years. She handled a complex civil enforcement caseload, and prosecuted a wide array of environmental criminal cases during her tenure a the EPA. She was also appointed as a Special Assistant U.S. Attorney (SAUSA) for the U.S. District Court for the Eastern District of Pennsylvania.
As Assistant Regional Counsel for the USEPA, she provided legal counsel to the Regional Superfund Program office and handled all aspects of a civil enforcement caseload. She provided litigation support to the Department of Justice in federal hazardous waste enforcement actions under Superfund and the Resource Conservation and Recovery Act (RCRA). She negotiated settlements in multi-party Superfund cases with Potentially Responsible Parties (PRPs) numbering in the hundreds. She also handled several multi-party CERCLA cost recovery actions, leading the litigation team or facilitating settlement of the cases.
Within USEPA Region III, she served as a regional expert on Institutional Controls and Brownfield’s issues, providing support and advice to other regional staff. She handled complex RCRA enforcement matters and administrative cases, including appeals to the Environmental Appeals Board in Washington, D.C.
Sarah served as legal counsel to the EPA Region III Criminal Investigation Division (CID). She assisted in the investigation of federal environmental and Title 18 crimes, including: air, water, pesticides, hazardous waste, asbestos, vessel pollution, mail fraud, wire fraud, and federal false statements.
As an attorney in private practice prior to her government career, Sarah performed in-depth analyses of the RCRA “land ban” regulations, organized and presented summaries of pending court challenges to the EPA “land ban” rulemakings, and drafted federal appellate briefs. She wrote and published articles on the applicability of federal procurement law to Superfund mixed funding agreements. She evaluated various Superfund consent decrees and liability issues, developed factual support for use in CERCLA cost recovery actions, and submitted one of the first “Petitions to Cancel” a pesticide registration under FIFRA.
Sarah also served as General Counsel to an environmental consulting firm specializing in engineering, subsurface evaluations, underground storage tank management and closures, environmental compliance audits, Phase I and II site assessments, permitting, and environmental remediation. She provided advice to clients on federal, state, and local regulatory requirements, and assisted in the firm’s marketing efforts.
Founder, Women Empowering Women, a non-profit committee focused on homeless women and children in the City of Philadelphia.
Member, University of Pennsylvania Abramson Cancer Center, Director’s Leadership Council.
Contributor, City of HOPE Cancer Center, Events Committee.
Member, Archdiocese of Philadelphia Parish Advisory Subcommittee.
Member, Forum of Executive Women.
Committee Member, Tara Miller Melanoma Foundation.
Member, Society of Women Environmental Professionals (SWEP)
- Registered Professional Engineer, PA, NJ, DE, NY, MA, MD
- US Green Building Council, LEED-AP
- PADEP Certified for Storage Tank Closure Activities
- NJDEP Certified for Underground Storage Tank Systems
- NJ Subsurface Evaluator
- USEPA Lead Certification
- B.S., Civil Engineering, Northeastern University, 1973
- M.S., Civil Engineering (Environmental Engineering Spec.), Northeastern University, 1977
Fields of Competence
- Management and direction of projects performed under major federal and state environmental programs
- Brownfield site reuse/redevelopment projects
- Industrial site assessment, investigation and remediation
- Underground storage tank management
- Property acquisition due diligence, including environmental assessments and subsurface evaluations
- PCB transformer/TCSA compliance projects
- Design, construction, permitting, operations, and maintenance of environmental systems
- Expert witness testimony
- Stormwater Management and selection of BMPs
- Site selection, planning, engineering, and design associated with “Green” building and “LEED” projects
Keith has over thirty years of technical and managerial experience with an international architect/engineering firm and with environmental consulting services firms, including over 20 years as the President of two successful environmental firms that performed projects on a nationwide basis.
He has served as a lecturer at conferences and training seminars, speaking on the subjects of environmental investigations and remediation, corrective action technologies, management of underground and aboveground storage systems, Brownfields revitalization and PCB transformer risk management.
Keith was elected Township Supervisor for a municipality of approximately 20,000 residents. In that role, he oversees, directs, and provides service in all areas of government including public health, safety, welfare, finance, planning, parks and recreation, land-use and land development and constituent services.
- Township Board of Supervisors, West Whiteland Township, Chester County, PA (2000-2013).
- Director, Downingtown Area Regional Authority (1995-2001).
- Chairperson, Municipal Services Commission, West Whiteland Township (1988-2000).
- “Point of Entry Carbon Systems for the Removal of Volatile Organic Compounds,” Proceeding, ACSE National Conference on Environmental Engineering, 1987.
- “Bringing Contaminated Industrial Real Estate Back into Service,” Proceedings, Hazardous Waste Cleanup Conference, Continuing Legal Education, 1994.
- “A Developer’s Approach to Brownfields Projects”, CLE International Conference on Owning, Developing & Managing Contaminated Property, December, 1997.
Brownfields: Management and direction of Brownfields reuse/redevelopment projects for public and private developers. Projects have included development of strategies to secure the property, environmental investigations, remediation, public participation programs, funding applications and obtaining regulatory agency releases of liability.
Assessments and Investigations: Provided comprehensive services for minimization of environmental risk and ensuring regulatory compliance for numerous clients and properties. Activities included Phase I Assessments and Phase II Site Investigations, remedial actions and regulatory agency interface.
Lead: Technical Manager for a first of its kind project to evaluate the presence of lead in drinking water in 300 schools and buildings within Philadelphia, the nation’s 5th largest public school system. Developed sampling plans and remedial plans and interfaced with regulatory agencies (Federal, State and local) and the media. Provided similar services for the Baltimore City Public School System and for several charter schools.
Superfund: Managed a number of Superfund investigation, design and remedial projects for a large pharmaceutical company. Directed all home office and remedial activities for operations and maintenance of a soil and groundwater treatment system for a $20+ million PRP-financed Superfund site remediation project and for a groundwater remediation project incorporating numerous point-of-use water treatment systems.
Transformers: Technical direction of comprehensive PCB transformer projects including a city-wide project for the Philadelphia School District. Project required the inspections of approximately 100 locations, development of a PCB Transformer Management Plan, testing, sampling, transformer replacement, remediation and regulatory agency interface.
Technical Oversight: Technical oversight of a $15 million PCB TCSA investigation and cleanup at a major aluminum extrusion facility that was built prior to World War II. Project included lagoon closures, soil and groundwater investigations, floor and worker surface contact sampling, transformer area sampling, and remediation.
Expert Witness Testimony: Provided expert witness testimony regarding storage tanks, asbestos, PCB transformers, soil and groundwater investigations, and hazardous waste remediation.
Emergency Remedial Response Actions: Experience directing and managing a full scope of remedial services (engineering, field services, regulatory agency interface, turn-key operations) for a wide range of incidents. Assignments have included the remedial assessment of the National Enquirer’s anthrax impacted building (Boca Raton, FL), evaluation of properties immediately following hurricane Katrina, mercury spills in school buildings, leaking underground and above ground storage tank systems, releases/spills of solvents, gaseous releases, accidental asbestos releases and other similar types of incidents.
Chris has 20 years of experience providing environmental consulting, construction management and real estate development services to both the private and public sectors. His experience includes the implementation and management of remedial investigations and corrective action activities at CERCLA, RCRA municipal and industrial sites. He has worked on Brownfield revitalization projects under the regulatory oversight of numerous State agencies, and supervised the closure/remediation of both aboveground and underground storage tanks. Chris has significant experience conducting environmental site assessments and property condition assessments in support of real estate transactions, as well as with the performance/development of asbestos investigations, management plans, and asbestos abatement projects.
Former Chair of the Environmental Advisory Council, East Vincent Township, Chester County, PA, (2008-Present).
Former President, Green Valleys Association.
Political Committee Leader, East Vincent Township.
“The Top Ten Reasons Why Brownfield Redevelopment Projects Fail” , 2006.
“Recognition of Milankovitch Orbital Forcing Patterns in Shelf Facies of the Lower Devonian New Creek and Corriganville Formations” , 1995.
“The Geology of Fairmount Park,” The Guide to Fairmount Park, 1995.
“The Case for a Process Determined Hierarchy of Allocycles”, 1992.
Chris served as the Senior Project Manager for a complex remediation project in Morris County, New Jersey. The site was a former industrial facility with chlorinated volatile organic-impacted soil and groundwater. The groundwater remediation system was operational for many years and was eventually shut down in favor of monitored natural attenuation, one of the first such projects in the State of New Jersey.
Chris was the Senior Project Manager for environmental matters concerning a multi-million dollar real estate transaction along the waterfront in Delaware County, Pennsylvania. The work involved the removal of a 30,000 gallon bunker fuel underground storage tank and the transport and disposal of 3,000 tons of historical fill. All work was completed within two weeks, including the hazardous characterization of the fill material.
Chris was the Senior Project Manager for a project located in Franklinville, New Jersey involving the release of chlorinated solvents and PCBs to groundwater. He performed a comprehensive subsurface investigation and hydrogeologic study and prepared numerous reports for submittal to regulatory agencies. The project involved several potentially responsible parties and the complex relationships between these PRPs.
As Senior Project Manager a large marine terminal in Eddystone, Delaware County, Pennsylvania to complete a due diligence review for a pending multi-million dollar real estate transaction. The project involved the review of all in-house environmental files and permits and a file review with the Pennsylvania Department of Environmental Protection. The due diligence review identified a 30,000 gallon bunker oil underground storage tnaks and a 4,000 ton soil/debris pile. Both issues were addressed in three weeks to facilitate the real estate transaction.
Vadose Zone Modeling
Chris has worked as a Project Modeler developing soil cleanup standards for a dewatered zone of perched-water at a Superfund Site on St. Thomas, U.S.V.I. The client was one of several PRPs identified by the EPA as a source of the groundwater contamination in the Tutu Valley.
Chris has directed and managed Brownfields reuse/redevelopment projects for both public and private developers in the State of Pennsylvania. He was designated as the “professional in responsible charge” for the completion of more than 30 sites under Pennsylvania’s Act 2 regulations.
For a Land Recycling Project located on the Philadelphia waterfront where the site was a former industrial facility when the soil and groundwater was contaminated by metals and petroleum compounds. The site contamination mitigated via pathway elimination techniques. The intended end-use for the property is a Center City Casino and high-end entertainment establishment.
Chris was the Senior Project Manager for a Land Recycling Project involving the redevelopment of the US Postal Service Facility located at 30th and Chestnut Streets in Philadelphia. As the lead professional for the project, Chris directed all work including; the installation of a shallow monitoring well network; performance of an aquifer test to assess hydrogeologic parameters; completing a formal technical submittal to PADEP requesting a reduction in quarterly groundwater attainment events from eight to four; completing a human health risk assessment that ensured a cancer exposure risk of less than 10-5; and the preparation and submittal of the Final Report to PADEP requesting Act 2 Liability protection for the constituents of concern in soil and groundwater. The PADEP approved the Final Report and granted the requested Relief of Liability
Fields of Competence
Asbestos, lead and hazardous material investigations related to building renovation and/or demolition projects.
Asbestos inspections required under the federal AHERA regulations.
Abatement project design to coordinate with building renovation/demolition plans.
Writing specifications to implement asbestos abatement projects.
Project management and oversight of abatement projects related to building renovation/demolition.
Management and oversight of EPA/AHERA asbestos inspection and abatement activities in elementary and secondary schools.
Coordination, development and implementation of LEED.
Preparation of Indoor Environmental Quality Management Plans related to asbestos, lead-based paint, mold and other contaminants.
Certified in NIOSH 582 Proficiency
Certified EPA/AHERA, Pennsylvania Asbestos Building Inspector
Certified EPA/AHERA, Pennsylvania Asbestos Management Planner
Certified EPA/AHERA, Pennsylvania Asbestos Project Designer
Licensed City of Philadelphia Asbestos Project Inspector
Licensed City of Philadelphia Asbestos Investigator
Licensed State of Delaware Asbestos Project Monitor
Certified EPA/HUD Lead-based Paint Risk Assessor
B.S., Business Administration, Widener University, 1983
Andy has more than 15 years of experience providing assessments of and solutions for enhancing Indoor Environmental quality. His expertise includes asbestos, lead-based paint, mold and other parameters. He has completed significant projects for educational facilities, government buildings, as well as industrial and commercial establishments. His expertise includes building surveys, specification/bid document writing, and procuring bids. He also has extensive experience in abatement project management and oversight.
Andy serves as the Archdiocese of Philadelphia’s Project Manager to ensure compliance with the EPA AHERA regulations in all schools within the Archdiocese. This multi-year project included the management of an EPA-approved work plan designed to bring more than 200 elementary and secondary schools into regulatory compliance. The project included the coordination of inspection activities for by three subcontracted consulting companies, assessing the need for abatement and remediation, activities, collecting bids, and performing oversight of air monitoring and abatement personnel.
He also served as Project Manager for asbestos and lead-based paint assessments and pre-demolition abatement of multiple buildings that comprise the former Main U.S. Postal Facility at 30th Street in Philadelphia, PA. This multi-year assignment involved three separate buildings and represented in excess of 1.2 million ft2 of building area. As the Project Manager, Andy directed all inspection and sampling activities, prepared required reports, and developed specifications and cost estimates. Additionally, during the abatement activities he provided oversight for required air monitoring and ensured contractor compliance with all applicable asbestos regulations including EPA, State of Pennsylvania and the City of Philadelphia Asbestos Control Regulations.
At the completion of the renovation phase of the former Main U.S. Postal Facility at 30th Street in Philadelphia, PA, Andy coordinated the development and implementation of the construction IAQ Management Plan for LEED Certification. A sampling plan was developed in accordance with the requirements of the U.S. Green Building Council New Construction and Major Renovation Reference Guide for Credit 3.2 of the LEED Certification program. Oversight was provided for the successful implementation of the sampling plan and achievement of the LEED credits.
Andy performed microbial/indoor air quality assessments at various educational, banking and health-care facilities in response to complaints of illness and nuisance odors. Microbial sampling, in the form of air, wipe, swab and water, was performed for various forms of mold, fungi and legionella. Documentation and reports were provided to aid in the evaluation of personnel issues as well as the performance of building systems.
For the expansion of the PA Correctional Facility at Graterford, Andy led a team of environmental specialists who evaluated a number of structures that required demolition. The evaluation included consideration of asbestos, lead-based paint, PCBs, and hazardous materials. Andy provides rapid, emergency response to environmental issues in schools and other buildings. He has coordinated, documented and provided remedial services for events such as water and sewage leaks, fires, floods, mold, damage to asbestos containing building materials and lad based painted surfaces, as well as to the release of oils and chemicals. He has worked closely with contractors, maintenance and facilities personnel to stabilize these situations. Following the initial response he has developed the remediation work plans, supervised their implementation and coordinated regulatory agency notification.
Andy has also served as Project Manager and Lead Inspector on school renovation projects for the Brandywine School District in Wilmington, DE. This multi-year project involved the complete renovation of two elementary school buildings, representing in excess of 250,000 of building area. Andy performed comprehensive pre-renovation asbestos surveys, wrote survey reports and abatement specifications relative to the building renovation plans, interfaced with personnel from construction management teams and various trades to design the abatement projects, and managed the abatement projects from start to finish including the performance of all required air monitoring tasks.
Andy designed and implemented a background sampling plan for asbestos, lead, total and respirable dust and volatile organic compounds prior to interior demolition activities at the Main US Postal Facility at 30th Street in Philadelphia, PA. The sampling established baseline levels relative to potential contamination caused by demolition work. Samples were also collected from occupied areas and other areas to gauge the level of cross contamination from demolition work.
Andy performed a background indoor air quality assessment of a newly renovated nursing facility for the Office of Catholic Social Services. The assessment established the baseline condition of the facility relative to potential indoor air quality and mold impacts. The assessment included the collection and analysis of air samples, the collection of relative humidity readings, and a visual inspection for mold growth. A detailed report was prepared which summarized the methods and procedures for sample collection, the results of the sample analyses, as well as conclusions and recommendations.
Andy also served as the Project Manager for The DuPont Company on the interior demolition and renovation of a 425,000 ft office building in Delaware. The project involved asbestos abatement relative to the interior demolition and renovation. Andy managed all asbestos abatement and air monitoring activities while ensuring abatement contractor compliance with all applicable regulations and project specifications.
He served as Project Manager and Inspector working for the Army Corp of Engineers to bring the Washington D.C. School District facilities into AHERA compliance. He inspected school buildings relative to maintenance work orders to determine the effects, if any, on asbestos containing building materials (ACBM). He wrote asbestos abatement specifications and oversaw the abatement and air monitoring activities.
Fields of Competence
Brownfield site reuse/redevelopment projects.
Phase I and Phase II Environmental Site Assessments and Investigations.
Development, implementation and interpretation of hydrogeologic investigations and data.
Fate and Transport modeling.
Design, installation and operation of soil and groundwater remediation systems.
Underground storage tank management, closure, assessment and remediation projects.
Natural attenuation application and evaluation.
Spill Prevention, Control and Countermeasure Plans.
Asbestos assessment and abatement programs.
Indoor air quality evaluations.
Site selection, planning and evaluations for “Green” building and LEED projects.
Professional Geologist, DE, PA, NC, VA
Licensed Site Remediation Professional (LSRP)-NJ
US Green Building Council, LEED – AP
Certified North Carolina Hazardous Waste Site Manager
AHERA Certified Asbestos Building Inspector
City of Philadelphia Asbestos Inspector
Certified OSHA 29 CFR 1910.120
American Association of Engineering Geologists
American Association of Petroleum Geologists
National Groundwater Association
B.S., Geology, Colgate University, 1978
Graduate Coursework, Hydrology, Wright State University, 1992
Stuart has twenty-seven years of project management experience in the petroleum and environmental industries. His expertise is in the assessment, remedial design and implementation of corrective actions for soil, sediment and groundwater contamination. Stuart has extensive experience with environmental projects conducted under Federal (CERCLA, RCRA), Brownfields and State voluntary programs in PA DE, NJ, VA, NC, IL, OH, and SC.
Stuart’s experience as a License Site Remediation Professional (LSRP) in New Jersey includes the preparation of Preliminary Assessments (PAs), Site Investigations, Work plans, Remedial Investigations (RIs), Remedial Action Reports (RARs) and Response Action Outcomes (RAOs). He has successfully completed projects resulting in RAOs for both impacted industrial sites and for childcare licensing. He has also served as an expert witness in a legal proceeding involving impact to private water supply wells from a chlorinated solvent release at an industrial facility.
Industrial Site Remediation and Brownfields Redevelopment:
Stuart was the Project Manager and lead Hydrogeologist for a New Jersey School Development Authority redevelopment project involving the $7.5 million assessment and remediation of a former industrial waste disposal site. He employed The Triad approach for rapid site assessment. Stuart developed a cost-effective remedial approach employing hazardous waste stabilization, existing building decontamination and installation of engineering/institutional controls to address residual soil and ground water contamination. The site was restored and redeveloped as a community park providing both active and passive recreational facilities to community residents.
Stuart also obtained Brownfield certification and PA Act 2 closure for a former industrial property with chlorinated solvent and petroleum impacts to both soil and groundwater. He designed and executed the Remedial Investigation with associated vapor intrusion and fate and transport analyses that resulted in proper regulatory closure of the site and liability relief for the owner.
Stuart has also worked on behalf of KEM clients to obtain state funding grants to complete the assessment of a 65-acre former manufacturing facility impacted by wide spread low-level radioactive waste and organic/inorganic contamination as part of large community redevelopment project. The redevelopment plans have transformed this formerly abandoned site into the keystone of a large river front project providing mixed residential, commercial and recreational facilities.
Environmental Compliance Auditing
Stuart developed and implemented corrective/ environmental actions to address violations and deficiencies identified at a college during the performance of a USEPA-sanctioned compliance audit. The scope of the audit encompassed all of the major state and federal environmental regulatory programs.
Stuart has developed management and control systems for a large municipal school district to identify and remove their obsolete and unused chemical inventory.
He has facilitated the licensing of child care facilities in New Jersey through preparation of Preliminary Assessments and related documentation.
Stuart is a member of an environmental compliance audit team that evaluated numerous chemical, textile, and furniture manufacturing facilities on behalf of a large corporate client.
Asbestos and Indoor Air Quality
Stuart was the Project Manager for numerous projects that included asbestos surveys as well as indoor air quality evaluations, mold assessments and remediation work. These projects have included apartment complexes, universities, schools and churches. He has developed reports evaluating conditions and has provided recommended remedial options and cost estimates and provided on-site management of remedial activities.
Assessments and Investigations
Stuart has provided comprehensive services to numerous clients to aid in the minimization of environmental risk at their properties and to ensure overall regulatory compliance. On their behalf, he has conducted Phase I Assessments and Phase II Site Investigations, remedial actions and represented his clients with the regulatory authorities.
Emergency Remedial Response Actions
Stuart has significant experience directing and managing remedial services projects (rapid assessment of extent of contamination, emergency containment, regulatory agency interface) for storage tank overfills, spills and chemical releases. His projects have included chemical spills in school buildings, leaking underground and above ground storage tank systems, releases/spills of solvents, gaseous releases, accidental asbestos releases and other types of incidents.
Stuart served as a hydrogeological technical advisor under the USEPA Technical Assistance Services to Community (TASC) program to provide independent data analysis and interpretation to local Community Action Group (CAG) for the BoRit Superfund Site. He prepared and delivered presentations to the CAG and concerned community members that addressed concerns regarding the adequacy of the Remedial Investigation and the potential for the migration of on-site asbestos, inorganic and organic contaminants into the fractured aquifer supplying the public water system. His PowerPoint presentation was subsequently posted by the EPA on the BoRit website.
Spill Prevention Control and
Stuart served as the Area Project Director for a nationwide telecommunications provider’s SPCC program. He provided oversight of and reviewed the field activities of a team responsible for the preparation and implementation of SPCC plans at facilities in PA and NY. In addition, these projects included the on-site training of company personnel.