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spread on his property. Mr. Silva indicated that he was. Mr. McClellon asked Mr. Silva to meet with him at the site regarding this issue. Mr. Silva indicated that he would. Mr. Maldonado left and promised to return when Mr. Silva arrived. Mr. Backus and Mr. McClellon drove around the property, and looked for any other areas showing chicken manure disposal. The property to the east(APN 023-250-02) also belongs to Gary Silva. This property also showed evidence of disposal of solid chicken manure. The chicken manure was mostly dry, but had not been incorporated as required by San Joaquin County Ordinance Code. When Mr. Silva arrived at the property, Ms. Oldfather asked Mr. Silva a series of questions regarding the discharge. Mr. Silva stated that SKS Farms was giving him the manure as a favor. Mr. Silva said that the manure was being used to build up the land. Mr. Silva also said that he has planted a clover mix on the property to take up some of the nitrogen from the manure. Mr. Silva stated that he had worked the property and removed a lot of the cobbles. This was not apparent at the time of the inspection. Mr. McClellon asked Mr. Silva if he was tracking the amount of manure he was putting out on the property. He stated that he was not. Mr. McClellon asked him if he had any intention of moving the pipe, and he stated that he did not. Mr. McClellon asked him how he planned to spread the liquid manure, as he did not see a sprinkler system or sprayer. Mr. Silva stated that the manure would be dispersed along the pipe through the individual gates. Mr. McClellon explained that the liquid appeared to flow toward the low.spots along the contour of the slope and concentrate there, while the high spots did not appear to receive any liquid manure at all. Mr. McClellon asked Mr. Silva how many trucks per day came to his site from the SKS facility. He was not sure. Mr. Maldonado answered that three trucks brought the dry manure from their operation to the site. Mr. Backus asked Mr. Maldonado if they used a different truck to bring the wet manure out to the site. Mr. Maldonado indicated that they did use a different truck. Mr. Backus asked how many truckloads of wet manure were brought to the site each day. Mr. Maldonado indicated that three truckloads of wet manure were delivered to the site each day. Mr. McClellon asked Mr. Maldonado who owned the trucks, and he said that SKS Farms owned the trucks. Mr. McClellon asked Mr. Maldonado who paid for the fuel for the trucks, and he responded "SKS Farms." Mr. McClellon asked Mr. Maldonado whose employees drove the trucks, and he responded "SKS Farms." Mr. McClellon asked if they used the Silva property as a primary disposal site or as a back up site. Mr. Maldonado stated that they would use the dry pad area owned by SKS Farms if they could not use the Silva site. Mr. Silva asked what the problem was; saying it is just chicken manure. Mr. McClellon explained that it was a matter of waste management, and it looks like he is in the business of waste management. Mr. McClellon explained that because Mr. Silva did not have an exemption from the requirement for a solid waste facility permit, he was in violation for operating without a , permit. Mr. McClellon explained that since he was not incorporating the manure into the soil within 24 hours after spreading, this was another violation, and that fly breeding was also a violation. Mr. McClellon explained that because he was not tracking the amount of manure being applied to the site, and it was impossible to ensure that there would not be an impact to surface or ground water. Mr. McClellon directed Mr. Silva to discontinue all discharge of chicken manure immediately. Mr. McClellon explained to Mr. Maldonado that SKS Farms was in violation of their approved manure management plan, because an unauthorized disposal site was being used. Mr. McClellon directed Mr. Maldonado to discontinue all discharge on to Mr. Silva's property immediately. Mr.