CWEA Member Profile: Mary Phelps, Source Control Inpector III, Busts Money Laundering Operation

Mary Phelps Source Control Inspector III, City of Richmond

Mary Phelps
Source Control Inspector III, City of Richmond

Mary Phelps, Source Control Inpector III, City of Richmond shares her experience as a Subject Matter Expert (SME) involved in the update of the Environmental Compliance Inspection (ECI) exam.

How did you get into this profession?

I was the Plant Chemist for a chemical manufacturing facility. The company was having difficulty meeting its wastewater discharge limits for the City of Richmond. After many Notices of Violations, the City decided to escalate enforcement against the company for multiple heavy metals violations.

I told our legal department the test methods the City was using at the time were not compliant with 40 CFR Part 136, so the results were rendered invalid. No penalties could be assessed based on the monitoring results.

The company still had to comply with the local limits, which resulted in several million dollars in construction costs. A year later, during the company’s annual compliance inspection, our Inspector told me she was leaving and I should apply for the position. I told her the City would never hire me based on “our history,” but I applied anyway.

I left the chemical company and went to work for the City of Richmond in December 1991.

What was your career path?

After leaving college, I worked for companies that had wastewater discharge permits. It started with food manufacturing, then sulfuric acid manufacturing, sodium silicate and Epsom Salt manufacturing, and, finally, pesticide manufacturing. After working on the opposite side of regulatory agencies, I began to realize that it might be more interesting to enforce the regulatory laws than to be the ones to constantly have to comply with them. So, I left the manufacturing world and entered the regulatory world.

How long have you been involved with CWEA?

I started with the City in December 1991. It was frustrating trying to learn on the job. I had studied 40 CFR 403, but it did not provide much insight. My supervisor suggested I enroll in the Pretreatment Facility Inspection course. I passed the Ken Kerri course in January 1994 and took the Grade I certification test in January 1995.

Then, I was allowed to attend one of the CWEA conferences. I have been involved with attending conferences and trainings and earning my certification(s) with CWEA since then.

What was your role in the Environmental Compliance Inspector exam update?

An all points email was sent out to those who held certifications asking if they would be interested in revalidating the exams. I hold a Grade IV in Environmental Compliance.

What is the hardest part of being a subject matter expert?

Writing competent questions that make sense.

What is your personal goal as a subject matter expert?

To provide exams that truly measure the competency and knowledge of the certifications that we have established with current up-to-date technology, treatment information and regulations

Where do you see certification in water and wastewater going in the future?

Hopefully, most municipalities will see the value in obtaining certification from CWEA and will require it for the inspector positions they have within their district or municipality. Several districts (Richmond included) already require it within 12-18 months from the date of hire.

Would you recommend this profession to others?

This is a great field to get into right now. It is always changing, never boring, and you will most likely always have a job. Everyone needs to get rid of wastewater. I think special districts are somewhat better than cities for employment opportunities.

What is the craziest story you have encountered in your work?

We had received a call about a money laundering operation that was happening in our district. Allegedly, there was a warehouse that was discharging all kinds of weird stuff and huge trucks would show up at all hours of the night offloading huge crates. My coworkers and I thought that we had stumbled upon some huge counterfeit operation. We were really excited that we might “bust” something that we would get to report to the Secret Service.

We showed up at this warehouse, showed our Code Enforcement badges and said we needed to inspect the facility regarding its high water usage.

The manager was more than happy to have us come inside and take a tour. My coworker and I thought, “This is strange, not even trying to hide anything.” The manager took us on a full tour of the facility. We saw the large trucks that were unloading large crates.

As it turns out, this huge money laundering operation really was a money laundering operation. They were washing coins that were removed from fountains at the local shopping malls. It was a non-profit organization that would then put the money back into local boys and girl clubs.

Needless to say, my coworker and I took a sample (just in case for heavy metals), explained the problems with discharging heavy metals, chemicals, etc., left them with a permit application, and came back a week later with their discharge permit. All they had to do was treat for pH adjustment… no heavy metals. So that was our big money laundering operation. What a disappointment, but it was good for a few laughs.


Are you interested in becoming a Subject Matter Expert? Contribute your expertise by becoming a volunteer contributor to the certification program for your vocation. Help others and help our profession by contributing any amount of time you can.

For details contact Chris Lundeen at clundeen@cwea.org.

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Chris Lundeen

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