Cases
Experience: Representative Matters: Petitioned the EPA for approval of new renewable fuel
prepared petitions for new renewable electricity producers.
Defended multinational manufacturer in Federal Communication Commission (FCC) enforcement action
assisted in the development of an FCC compliance plan.
Advised clients responding to emergencies (including fires
accidents).
Defended energy company in civil judicial enforcement action related to alleged stormwater violations.
Advised manufacturing start-up on environmental
DOT issues related to product distribution.
Defended client in complex state RCRA enforcement action
developed successful plan for federal intervention.
Assisted data
cloud center clients with complex air permitting, compliance
enforcement issues related to need for uninterrupted sources of backup power.
Defended multiple clients in mobile source enforcement actions under the Clean Air Act.
Assisted multinational electronics manufacturer with CAA compliance audits to obtain full penalty mitigation under federal
state audit policies
programs.
Performed environmental due diligence on large commercial real estate
M&A transactions.
Counseled clients on imports compliance under the Toxic Substances Control Act
the Clean Air Act.
Assessed
described material regulatory risks for SEC filings.
Advised multiple clients on strategic use of FOIA
the federal Information Quality Act.
Advised large agribusiness on Clean Water Act compliance requirements for concentrated animal feeding operations (CAFOs).
Developed, drafted
submitted successful comments on a proposed rulemaking that resulted in the inclusion of agricultural wastes
manure as approved cellulosic feedstocks under the EPA's Renewable Fuel St
ard (RFS) program.
Petitioned the EPA on behalf of trade association for approval of sorghum oil-derived fuels as advanced biofuels under the RFS program.
Advised large agribusiness on requirements for creation of first-in-class hog manure to energy plant.
Defended large beverage manufacturer in Clean Air Act enforcement action for alleged NSR/PSD violations.
Advised food
beverage industry companies on compliance with anhydrous ammonia
ODS requirements.
Obtained applicability determination from the U.S. Environmental Protection Agency (EPA) under the Clean Air Act for a client's new renewable energy gasifier.
Defended municipal wastewater treatment plant in federal enforcement action under the Clean Water Act
the Clean Air Act.
Drafted client comments on proposed EPA rule that led to favorable changes in final rule under the Renewable Fuel St
ard.
Defended clients in threatened
actual citizen suits under the Clean Air Act
the Resource Conservation
Recovery Act.
Assisted clients in performing environmental due diligence prior to purchase of contaminated property.
Broke through logjam
helped client obtain Federal Insecticide, Fungicide
Rodenticide Act (FIFRA) registration for pesticidal device.
Obtained full penalty
liability mitigation for clients disclosing
correcting environmental violations under federal audit policy
state analogs.
Conducted internal investigation
successfully defended health care institution in Nuclear Regulatory Commission investigation of unfounded whistleblower claims.
Evaluated NEPA
other claims to assist client in obtaining secured bond financing for public transit project.
Represented whistleblower corporation in federal investigation of competitor engaged in criminal fraud under the Renewable Fuel St
ard.
Litigated toxic tort claims on behalf of persons exposed to excess radiation from nuclear weapons plants.
Counseled clients on environmental compliance under all federal environmental statutes.
The above representations were h
led by Ms. Rappold prior to her joining Greenberg Traurig, LLP.
Noteworthy Experience: Director, Environmental Protection Agency, Office of Enforcement
Compliance Assurance, Special Litigation
Projects Division, 2008-2013
Director, Environmental Protection Agency, Office of Enforcement
Compliance Assurance, Federal Facilities Enforcement Office, Site Remediation
Enforcement Staff, 2001-2008