SUSAN V. HARRIS practices in all areas of environmental law, but has significant experience in the areas of the Clean Air Act, environmental management, and the Emergency Planning and Community Right-to-Know Act. Ms. Harris advises clients in a broad range of regulatory matters relating to environmental reporting, air, water, and pesticides. She has also represented numerous clients in state and federal enforcement proceedings, internal investigations, criminal investigations, and defended several clients in environmental citizen suits.
Of Particular Interest
In 2008 and 2009, Ms. Harris was recognized by The Legal 500 as “tops in litigation strategy and client responsiveness.” Ms. Harris has also served on the Environmental Council of a major multi-national food and textile company for more than five years. In that capacity, she has assisted the company in designing and implementing environmental management systems, including auditing, training, and compliance programs.
- Assisted a major petroleum company in connection with US EPA’s NSR petroleum enforcement initiative, including responding to Clean Air Act information requests and developing strategy for settlement negotiations.
- Represented a number of international pharmaceutical companies in federal enforcement actions involving alleged violations of the Clean Air Act NESHAP and Leak Detection and Repair programs.
- Represented and advised various clients in state and federal enforcement actions involving alleged violations relating to air permits (Title V, construction, and other operating permits), effluent discharges, release reporting, and EPCRA.
- Defended a petroleum refining company against claims by the United States of violating the Benzene Waste Operations NESHAP.
- Represented a metal recycling company in federal court litigation relating to Clean Air Act and Consent Decree compliance matters under the NESHAP program.
- Representing a company in criminal investigations relating to its Clean Air Act compliance and recordkeeping practices.
- Represented a major food and textile company in a company-wide voluntary disclosure under US EPA’s audit policy regarding toxic air releases and other allegations of non-compliance raised by a disgruntled employee. Matter was resolved with no penalty or follow-up action required.
- Conducted internal investigations for multinational companies relating to air and EPCRA compliance issues.
- Managed internal multi-media audits for various clients, as well as targeted internal compliance audits relating to the Clean Air Act CFC and EPCRA reporting programs.
- Assisted numerous manufacturing companies (including plastics, petroleum, printing, pharmaceutical, cement, and bakeries) in obtaining, structuring, and managing their Clean Air Act Title V permits and synthetic minor air permits.
- Assisted global manufacturing company design, develop and implement multi-level environmental compliance, management and auditing programs.
- Assisted various clients evaluate their existing environmental management systems against internal and external criteria.
- Developed and conducted corporate- and plant-level training programs covering each of the environmental media. Goals of the programs included to increase awareness of environmental issues in all areas and levels of corporate functions and to increase understanding of and compliance with environmental requirements.
- Counseled a major textile company in matters relating to general product regulatory compliance and use of antimicrobial agents.
- Assisted in defending a major petroleum refining company in a RCRA citizen suit relating to hydrocarbon contamination at and near a former refinery, including in an adjacent river.
- Assisted in defending an international pharmaceutical and healthcare company in a RCRA citizen suit relating to mercury contamination in river sediments.