(C)  State Offenses.  State laws frequently have parallel criminal offenses.  For example, in California, it is illegal to dispose of hazardous waste without a permit.  This is a general offense, applying to anyone who does so in violation of law.  This is a safe haven, and does not trigger any ground of deportation.  (A similar offense that has as an element a relationship with the manufacture of controlled substances would not be a complete safe haven, since it might be considered a conviction of an offense relating to a controlled substance, and thus trigger deportation under this ground.  See § 9.11(G), infra.)[116]

[116] INA § 237(a)(2)(B)(i), 8 U.S.C. § 1227(a)(2)(B)(i).

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