The Round Hill Club - Connecticut - Best In State Golf Course (top100golfcourses.com)
Introduction
Round Hill Country Club was originally founded in 1959 as a combination golf course and luxury housing community. The course was opened in fall of 1960, followed by the clubhouse, tennis facility and pool in 1961. The Round Hill area began as a "backcountry" farming region of Greenwich, populated by English settlers who moved inland from its coastal areas, and by Dutch settlers from New Amsterdam and the Province of New York, both of which contested control of the area through the late 17th century.1
Currently the facility uses secondary treatment with chlorine disinfection to treat effluent before being discharged into an irrigation pond in the Byram River Watershed which in turn is used to irrigate the golf course. The continuance of this permit and the ability to treat the discharge will protect the waters of the state from pollution.
1 Round Hill Historic District - Wikipedia
March 4, 2021
Laura Macklin, Associate in Arizona
Environmental Review, Inc.,
1792 Rogers Avenue, San Jose, CA 95112
Dear Laura Macklin:
We received your letter dated February 11, 2021 with comments and questions related to the public notice of the Round Hill Club Permit Number: CT0100986 and the related Application Number: 201702954.
Please find our responses following each of your comments/questions below:
1) Is the Irrigation Pond in the Byram River Watershed Lined or unlined? And would Surface Water Rules Apply?
Surface water rules have been deemed to apply because the pond is equipped with an overflow structure that has the capability of discharging into the Byram River watershed.
2) Section 1: General Provisions (A): add the acronym US EPA and carry it through the document.
Comment accepted.
3) Section 1 (B): Calls attention to the Connecticut General Statutes (CGS) Section 22a-430-3 and list the General Conditions (a)-(r) but in the rule it lists Section 22a-430a trough 22a-430c. Please verify and correct reference so it is easier to locate in the rule.
The Statutory and Regulatory references used in the permit are correct. The first sentence of section 1 (B) states in part: “ . . . this permit including the following sections of the RCSA which have been adopted pursuant to Section 22a‑430 of the CGS . . .”.
4) Section 1 (B): Calls attention to Section 22a-430-4 and lists the Procedures and Criteria (a)-(t) but in the rule there is no 22a-430-4. Please verify all section references throughout the document and correct where necessary so they are easier to locate in the rule.
Please see answer to 3 above.
5) Throughout the draft permit there is reference made to Section numbers but the Chapter, 446K is only mentioned one time in the first paragraph. It may be clearer if the Chapter is mentioned more often or somehow noted that all sections reference a particular chapter.
Change is deemed unnecessary as all sections are referred to RCSA or CGS.
6) Section 1 (H): Section 22a-430-7 for annual fees but in the CGS, there is no -7 but contains 430a, 430b and 430c. The reference should direct the permittee to the specific chapter and section which serves to avoid confusion when trying to comply with the rule.
Section 1 (H) states in part: “. . . as set forth in Section 22a‑430‑7 of the RCSA . . .” not the CGS. No change is necessary.
7) In the interest of time, and as to not call out all of the section references - Section number references in the draft permit do not mirror the section numbers and location in the CGS.
All of the section references should be verified with their location in the CGS.
Section references are all related to the RCSA as noted in Section 1 (B) unless otherwise noted.
8) 8) Section 2: Definitions: Consider adding Privately Owned Treatment Works (POTW). Also, see comment # 11 below.
Privately Owned Treatment Works (POTW) is added to section 4 (A).
9) Section 2: Definitions: Consider adding Biological Oxygen Demand (BOD).
Biochemical Oxygen Demand 5 day (BOD5) is added to section 4 (F).
10) Section 4: General Limitations and Other Conditions (A): Calls attention to Section 22a-6k which is found in Chapter 439 of the CGA and should be included in the reference since it differs from all previous Section references from Chapter 446k up to this point.
“of the CGS” has been added to all three references in section 4 (A).
11) Section 4 (A): Privately Owned Treatment Works can be abbreviated as POTW throughout the permit, after first mention.
Comment accepted.
12) Section 4 (C)(5): “except as may result discharge from a wastewater treatment facility”. Consider rewording “except as a result of the discharge from…”
The language has been reworded.
13) Section 4 (C)(6): RCSA §§ 22a-426-1—22a-426-9 is referenced here, and it appears there may be some confusion between the section numbering in the CGS and the Regulations of Connecticut State Agencies (RCSA). Please review references to their specific rule.
RCSA refers to the Regulations of Connecticut State Agencies as stated in the first line of the permit. As you note in your comment above “RCSA” is referenced with 22a-426-1 – 22a-426-9 in section 4 (C)(6) as it is related to the Water Quality Regulations not the Connecticut General Statutes (CGS).
14) Section 4 (F): Total Suspended Solids can be abbreviated (TSS) and explained in Section 2: Definitions which has been abbreviated throughout.
The language in Section 4 (F) has been edited to the abbreviations.
15) Section 4 (J): BOD5 is first mentioned here and should be spelled out as Biological Oxygen Demand and then abbreviated throughout the document.
BOD5 is first mentioned in Section 4 (F) as Biochemical Oxygen Demand and is abbreviated in Section 4 (J).
16) Section 6: Sample Collection, Handling and Analytical Techniques (B): Acute Aquatic Toxicity (Test) is mentioned 22 times throughout the draft permit. Could it be abbreviated as AATT and added to the definitions section?
DEEP prefers to leave it as is for clarity.
17) Section 6 (B)(1)(i): insert a comma between specific conductance and total alkalinity.
The missing comma has been added.
18) Section 6 (B)(4)(a): spell out NOAEL here as its first mention and use the acronym thereafter. Consider defining it in Section 2 (B): Definitions
It is spelled out in Section 2(A) where it is first mentioned:
SECTION 2: DEFINITIONS
(A) The definitions of the terms used in this permit shall be the same as the definitions contained in Section 22a‑423 of the CGS and Section 22a‑430‑3(a) and 22a‑430‑6 of the RCSA, except for "Composite" and "No Observable Acute Effect Level (NOAEL)" which are redefined below.
19) Section 8: Recording and Reporting of Violations, Additional Testing Requirements, Bypasses, Mechanical Failures, and Monitoring Equipment Failures (A): Consider revising the first sentence.
The word “indicates” was inadvertently removed. It has been replaced.
20) Section 8 (C)(1): Sewage Right-to-Know Bypass Reporting: Consider adding the acronym for all of the agencies listed here and carry throughout the document.
DEEP’s preference is to leave it as currently shown for clarity.
21) Attachment 1 - Table A: If applicable, consider listing the Minimum Level Analysis values in the last column, instead of having to refer back to Section 6.
DEEP’s preference is to leave it as currently shown.
22) Table C: Minimum Level Analysis: What is the significance of the * in the last column, and should it be defined in Table C Conditions? Or is it the same as the meaning for the * in Table F? Please clarify.
The asterisk in the last column has the same significance as the asterisk used in the last column of Table A. The heading of those two columns says “Minimum Level Analysis See Section 6”. The meaning of the asterisk used in Table F is explained at the bottom of Table F: “(*) required for composting or land application only”.
Please feel free to contact me with any questions or comments.
Sincerely,
/S/ Iliana Raffa
Environmental Analyst
Water Planning and Management Division
Bureau of Water Protection and Land Reuse
cc: Ian Critchley, Round Hill Country Club
Round Hill Club in Greenwich, Connecticut, USA | Golf Advisor (golfpass.com)
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Permittee: Round Hill Club, Inc Greenwich, Connecticut 06831 33 Round Hill Club Road Greenwich, Connecticut 06831 PERMIT #: CT0100986 APPLICATION #: 201702954 FACILITY ID: 057-006 201702954;
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February 11, 2021
Re: Permittee: Round Hill Club, Inc., Greenwich, Connecticut 06831, 33 Round Hill Club Road, Greenwich, Connecticut 06831, PERMIT #: CT0100986 APPLICATION #: 201702954 FACILITY ID: 057-006, Comments should be directed to This email address is being protected from spambots. You need JavaScript enabled to view it.
Dear Ms. Raffa,
Environmental Review, Inc. has reviewed the NPDES Draft Permit Renewal, Permit ID: CT0100986, Round Hill Club, Inc. Greenwich, Connecticut, dated February 15, 2021. and has the following comments:
Draft Permit:
1) Is the Irrigation Pond in the Byram River Watershed lined or unlined? And could Surface Water Rules apply?
2) Section 1: General Provisions (A): add the acronym US EPA and carry it throughout the document.
3) Section 1 (B): Calls attention to the Connecticut General Statutes (CGS) Section 22a-430-3 and then lists the General Conditions (a)-(r) but in the rule it lists Section 22a-430a through 22a-430c. Please verify and correct reference so it is easier to locate in the rule.
4) Section 1 (B): Calls attention to Section 22a-430-4 and lists the Procedures and Criteria (a)-(t) but in the rule there is no 22a-430-4. Please verify all section references throughout the document and correct where necessary so they are easier to locate in the rule.
5) Throughout the draft permit there is reference made to Section numbers but the Chapter, 446k is only mentioned one time in the first paragraph. It may be clearer if the Chapter is mentioned more often or somehow noted that all sections reference a particular chapter.
6) Section 1 (H): References Section 22a-430-7 for annual fees but in the CGS, there is no -7 but contains 430a, 430b and 430c. The reference should direct the permittee to the specific chapter and section which serves to avoid confusion when trying to comply with the rule.
7) In the interest of time, and as to not call out all of the section references - Section number references in the draft permit do not mirror the section numbers and location in the CGS. All of the section references should be verified with their location in the CGS.
8) Section 2: Definitions: Consider adding Privately Owned Treatment Works (POTW). Also, see comment # 11 below.
9) Section 2: Definitions: Consider adding Biological Oxygen Demand (BOD).
10) Section 4: General Limitations and Other Conditions (A): Calls attention to Section 22a-6k which is found in Chapter 439 of the CGA and should be included in the reference since it differs from all previous Section references from Chapter 446k up to this point.
11) Section 4 (A): Privately Owned Treatment Works can be abbreviated as POTW throughout the permit, after first mention.
12) Section 4 (C)(5): “except as may result discharge from a wastewater treatment facility”. Consider rewording “except as a result of the discharge from…”
13) Section 4 (C)(6): RCSA §§ 22a-426-1—22a-426-9 is referenced here, and it appears there may be some confusion between the section numbering in the CGS and the Regulations of Connecticut State Agencies (RCSA). Please review references to their specific rule.
14) Section 4 (F): Total Suspended Solids can be abbreviated (TSS) and explained in Section 2: Definitions which has been abbreviated throughout.
15) Section 4 (J): BOD5 is first mentioned here and should be spelled out as Biological Oxygen Demand and then abbreviated throughout the document.
16) Section 6: Sample Collection, Handling and Analytical Techniques (B): Acute Aquatic Toxicity (Test) is mentioned 22 times throughout the draft permit. Could it be abbreviated as AATT and added to the definitions section?
17) Section 6 (B)(1)(i): insert a comma between specific conductance and total alkalinity.
18) Section 6 (B)(4)(a): spell out NOAEL here as its first mention and use the acronym thereafter. Consider defining it in Section 2 (B): Definitions
19) Section 8: Recording and Reporting of Violations, Additional Testing Requirements, Bypasses, Mechanical Failures, and Monitoring Equipment Failures (A): Consider revising the first sentence.
20) Section 8 (C)(1): Sewage Right-to-Know Bypass Reporting: Consider adding the acronym for all of the agencies listed here and carry throughout the document.
21) Attachment 1 - Table A: If applicable, consider listing the Minimum Level Analysis values in the last column, instead of having to refer back to Section 6.
22) Table C: Minimum Level Analysis: What is the significance of the * in the last column, and should it be defined in Table C Conditions? Or is it the same as the meaning for the * in Table F? Please clarify.
Please direct your response to: This email address is being protected from spambots. You need JavaScript enabled to view it.
Sincerely,
Laura Macklin, Associate in Arizona
Senior Reviewer
Environmental Review, Inc., a 501(c)(3) Nonprofit Public Benefit Corporation
1792 Rogers Avenue, San Jose, CA 95112, http://www.envreview.org/
References and Document Links:
2. Round Hill Club, Inc., CT0100986, Draft Permit (epa.gov)
3. 2021January15RoundHillClubFactSheet.pdf