Problems Plague California’s Hazardous Waste VSP System
California is entering year three of the California Department of Toxic Substances Control’s (DTSC) Violations Scoring Procedure (VSP)—a novel permitting and enforcement scheme impacting all permitted hazardous waste facilities in the state. Problems with the process range from the inclusion of disputed violations in facilities’ scores to delays that have plagued DSc’s issuance and administrative review of scores. In addition, a number of facilities have sued DTSC, challenging their VSP score or challenging the regulations as a whole. Efforts are now underway to make the system more equitable.