(A)  In General.  When a defendant is charged with participating in the manufacture of controlled substances, most often methamphetamines, it is difficult to find a safe haven.  Most meth labs, however, are not overly discriminating in their choice of locations in which to dispose of the toxic chemicals resulting from the manufacturing process.  Not to put too fine a point on it, they dump their hazardous waste without securing proper permits from the proper environmental agencies.  This gives rise to the likelihood that there is a factual basis for a negotiated disposition to the offense of unauthorized disposal of hazardous waste.  In fact, it is becoming more common for prosecutors to charge these environmental violations in the first place, along with the manufacturing offenses, so the safe haven may already be charged as an offense against the defendant, making it even easier to secure agreement to a plea to this offense.

Ninth Circuit

SAFE HAVENS - HAZARDOUS WASTE - FEDERAL
United States v. Barken, ___ F.3d ___ (9th Cir. June 27, 2005) (sentence for unlawful transportation and disposal of hazardous material without a permit remanded under United States v. Booker, 125 S.Ct. 738 (2005)).
http://caselaw.lp.findlaw.com/data2/circs/9th/0350441p.pdf