Sarah Keating

Registration

  • 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

Credentials

  • 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.

Experience Summary

Professional

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.

Civic

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)

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