United States
                    Environmental Protection
                    Agency
Hazardous Waste Engineering
Research Laboratory
Cincinnati OH 45268
                    Research and Development
EPA/600/S2-86/030 Aug. 1986
c/EPA          Project Summary
                   A Requirements  Study  of  an
                   Automated  Advisory  System
                   for  Review of  RCRA Permits

                   J. N. Brown, M. E. Deerhake, R. S. Truesdale, and E. L. Fisher
                     Under the Resource Conservation
                    and Recovery Act, hazardous waste
                    management facilities must apply for
                    operating permits. Review by the U.S.
                    Environmental Protection Agency
                    (EPA) of the present backlog of permit
                    applications will cost approximately
                    $40 million. The objectives of this proj-
                    ect were to develop a conceptual de-
                    sign and implementation plan for an au-
                    tomated advisory system to make the
                    review process more uniform and pro-
                    ductive, and to aid in training new staff.
                    The conceptual design of the advisory
                    system is based on expert system tech-
                    nology. The system will be able to as-
                    sist reviewers in making decisions that
                    normally require expertise, in exercis-
                    ing analytical models and in generating
                    correspondence and reports. A three-
                    year implementation plan is proposed
                    that incorporates field tests of proto-
                    type advisory system modules after 6
                    months time and deployment of par-
                    tially completed advisory systems after
                    the first year. Plans for advisory system
                    maintenance, performance monitoring,
                    and feedback from permit  reviewers
                    are recommended.

                     This Project Summary was devel-
                    oped by EPA's Hazardous Waste Engi-
                    neering Research Laboratory, Cincin-
                    nati, OH, to announce key findings of
                    the research project that is fully docu-
                    mented in a separate report of the same
                    title (see Project Report ordering infor-
                    mation at back).

                    Introduction
                     As a result of the Resource Conserva-
                    tion and Recovery Act (RCRA) of 1976,
                    all hazardous waste management facili-
ties must apply for operating permits.
As of the end of 1985, the EPA Regional
Offices and states will have an esti-
mated backlog of more than 750 appli-
cations for operating permits. The re-
view of each permit application is
estimated to cost, on average, $52,000
in 1986 dollars, totaling approximately
$40 million over the next 3 to 4 years.
  Applications for operating permits
under RCRA are reviewed by EPA Re-
gional Offices  and state agencies to en-
sure that they satisfy all regulatory re-
quirements.  Many  of these
requirements are stated in terms of gen-
eral technical performance criteria. Both
detailed calculations and expert judge-
ment are often required from the permit
reviewer to determine whether the ap-
plication satisfies the criteria. Examples
of calculations that must be performed
include estimates of surface runoff to
check for protection against overtop-
ping of surface impoundments and
slope stability  analysis to ensure the
safety of dikes. Expert judgement is re-
quired in such  areas as evaluating the
chemical compatibility of synthetic
membrane  liners and evaluating the
protectiveness of a proposed facility
site.
  Currently, there is no uniform basis
for the review of RCRA permit applica-
tions. Variability is inherent in the inter-
pretation of information in permit appli-
cations and this variability can result in
an application's being approved in one
region and being denied in another. Ad-
ditionally, the  complex calculations in-
volved and the necessity of obtaining
outside expert consultation introduce
significant delays in the permit applica-
tion review  process.

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  Measures to enhance the productivity
and uniformity of the RCRA permit ap-
plication review process are being
sought by EPA. An automated advisory
system based on expert system tech-
nology can accomplish this goal.  To-
wards this end, the objectives of this
project were:
• to develop a conceptual design for a
  computer-based automated advisory
  system to assist in  the review of
  RCRA hazardous waste management
  facility permit applications;
• to determine and specify the re-
  sources required to develop, deploy,
  and maintain the automated advisory
  system; and
• to recommend an implementation
  plan.

Expert Systems
  The proposed advisory  system is to
be based on expert system technology.
Expert systems are computer programs
that solve problems normally requiring
the aid of an expert. An expert system
consists of a knowledge base, an infer-
ence engine, and a user interface. The
knowledge  base contains information
and experience possessed  by the expert
and additionally, the heuristics that the
expert uses in solving problems. The in-
ference engine consists of procedures
that draw inferences from the informa-
tion supplied by the user and from the
information stored in the system's
knowledge base. The user interface al-
lows the  user (e.g., the  permit applica-
tion reviewer) to communicate with the
expert system.
  The operation of an automated advi-
sory system based on  expert system
technology is as follows: The reviewer
enters general information and design
details concerning one section of a per-
mit application (e.g., dike  design). The
expert system  attempts to draw infer-
ences that confirm the acceptability or
identify deficiencies in the design. The
system may request additional specific
information about the design and oper-
ation of the facility being reviewed. The
conclusions of the expert system are
presented to the user in the form of rec-
ommendations and suggestions.

Conceptual Design  of the Advi-
sory System
  The functions performed by the per-
mit application reviewers include: find-
ing specific data and information in the
permit application; interpreting infor-
mation  presented  in the application;
performing calculations and exercising
analytical models; comparing data and
information in permit applications with
information found in regulations and
guidance documents; and making deci-
sions that range from the very simple to
complex ones requiring expertise.
  The conceptual design of the permit
review advisory system is presented in
block diagram form in Figure 1. The es-
sential components of the system are
the supervisory module/inference en-
gine, the user interface, and the expert
system library. These three major com-
ponents of the advisory system form a
single expert system and are the mini-
mum set of components for a working
system. The expert system library may
be thought of initially as a single expert
system knowledge base. It contains the
facts, heuristics, and system messages
associated with the review of one part
of a permit application. The working
memory associated with this knowl-
edge base stores case-specific data en-
tered by the user and the results of in-
ferences made by the expert system.
The supervisory  module/inference en-
gine performs all system control func-
tions and inference making. The user in-
terface provides for simple information
exchanges between the system and the
user.
  The analytical model  library is func-
tionally the same as the expert system
library. Each knowledge base in the ana-
lytical  model library contains  knowl-
edge about how to exercise a particular
model such as, for example, the EPA's
HELP (Hydrologic Evaluation of Landfill
Performance) model.  Among  other
forms of assistance in using analytical
tools, the system can assist the reviewer
in assembling input data sets and inter-
preting output data.
  The query/answer and explanation
subsystems are components of the user
interface. The query/answer subsystem
allows the advisory system to request
specific information that it needs and
allows the user to respond by entering
that information. The explanation sub-
system allows the user to request expla-
nations of the system's queries, infer-
ences, and recommendations.
  The  report  generator is a software
printer interface that formats various re-
ports based on the review of an applica-
tion. For example, if a deficiency  is
found in the completeness check of an
application, the  system can generate
correspondence to the applicant noting
the deficiency  and requesting the
specific information needed for the re-
view to continue.
  The DBMS interface to an external
data base is primarily for the storage of
data generated in  permit applications
reviews for later analysis and for incor-
poration in a data base of waste  man-
agement facilities.
  The advisory system can be imple-
mented in one of two configurations: a
separate module configuration and an
integrated system configuration. In the
separate module configuration, the ad-
visory system is a collection of individ-
ual expert systems each of which pro-
vides assistance to the reviewer in one
specific  part of the review process.
There is no communication between
the individual knowledge bases that
make up the expert system library.
  In the integrated version of the advi-
sory system, the supervisory knowl-
edge base contains the knowledge re-
quired to coordinate the  entire permit
application review and to provide to
each expert system access to knowl-
edge entered and inferred during previ-
ously executed expert systems. The
knowledge bases that form the expert
system library in the integrated system
are called task  knowledge bases. The
supervisory expert system knowledge
base also is referred to as the job knowl-
edge base.
  In the integrated advisory system,
two expert systems are operating in a
coordinated manner at the same  time.
The supervisory or job expert system
controls the overall review of a specific
permit  application. It controls the se-
quencing of task expert systems in the
detailed review of specific sections of
the application. The job expert system
provides communications between the
individual task expert systems such that
once specific  information  is entered by
the reviewer, it is available for use  by all
task expert systems.

Implementation Plan
  The recommended  implementation
plan schedule is shown in  Figure 2. This
schedule emphasizes the  need to pro-
vide assistance to permit reviewers as
soon as possible and to provide the as-
sistance where it is most needed.
  In the first year of the implementation
phase, the  basic modules of the  advi-
sory system are to be developed. These
include the supervisory module and in-
ference  engine, the user interface, and
four knowledge bases. The develop-
ment software will incorporate  basic
control (supervisory) functions and an
inference engine as well as user  inter-
face software modules.  The specific

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knowledge bases recommended to be
developed first are: synthetic liner se-
lection, waste analysis plan, the HELP
model, and permit application com-
pleteness check.
  It is recommended that EPA make the
decision to deploy the separate module
or the integrated configuration of the
advisory system at the end of the first
year of the implementation program. At
the end of the first six months, proto-
type modules of the advisory system
can be demonstrated in a Regional Of-
fice;  specifically, the completeness
check and waste analysis plan modules.
Early demonstration and test of the ad-
visory system by the end user, the per-
mit application reviewer, will allow their
recommendations to  be  incorporated
into the system as early as possible.
This early field test will facilitate the de-
ployment of partially complete advisory
systems in one  or more  Regional Of-
fices by the end of the first year.
           In the second year of the implementa-
         tion phase, additional high priority task
         knowledge bases will be developed. Ex-
         amples of appropriate knowledge bases
         include: cover systems, soil liners, and
         facility location information. Knowledge
         bases for  assistance in  exercising addi-
         tional analytical  models should be in-
         cluded. The final selection of specific
         knowledge bases to  be developed
         should be made following input from
         EPA Headquarters and, especially,  Re-
         gional Office staff. The  development of
         all remaining knowledge bases is to be
         completed in the third year.
           It is recommended that the advisory
         system be developed on symbolic pro-
         cessors using sophisticated  software
         development  tools and  be delivered
         using microcomputers. This approach
         allows EPA to take advantage of the fea-
         tures of symbolic processors during the
         development phase.  The  use of micro-
         computers as  the  delivery  vehicle
                   avoids the necessity of having to pur-
                   chase additional hardware in order to
                   deploy the system. The cost of transfer-
                   ring the knowledge bases from the for-
                   mat appropriate for the development
                   software to one appropriate for the de-
                   livery software will be small compared
                   to the cost of knowledge base develop-
                   ment.
                     Maintenance of the advisory system
                   will be required for the following rea-
                   sons: amendments to RCRA, user sug-
                   gested changes and enhancements to
                   the system, and system enhancements
                   resulting from new knowledge coming
                   from EPA research and development
                   projects. It is  recommended  that EPA
                   establish a capability for advisory sys-
                   tem maintenance within a contractor or-
                   ganization. This capability should be es-
                   tablished  in  the second  year  of the
                   development phase and should be, at a
                   minimum, one knowledge engineer
                   with  development hardware and  soft-
             Query/Answer
               Subsystem
    V  1 '
               Explanation
               Subsystem
       User
      Interface
                                                     Supervisory Module/
                                                       Inference Engine
             Job
          Knowledge
            Base
 r
    Expert System
                    i
         Task I
       Knowledge
         Base
  Task
Working
Memory
Expert
System
Library
                                                   Job
                                                 Working
                                                 Memory
                         	i
                                                                        Report
                                                                       Generator
                                                                        DBMS
                                                                       Interface
Analytical
 Model
 Library
External
 Data
 Bases
Figure 1.    Automated advisory system.

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ware; additional capability should  be
available on an as-needed basis.
  It is estimated that the development
of the four knowledge bases beginning
in the first year of  implementation will
require 44 person-months. Develop-
ment of the explanation module and  re-
port generator will require an additional
6 person-months as will modification of
the supervisory/inference engine.  Field
tests and demonstration of prototype
systems in Regional Offices will require
5 person-months; development of soft-
ware to demonstrate and test the inte-
grated advisory system  configuration
will  require approximately 11 person-
months.  Cost estimates for years two
and  three are 8 to 12 person-years of
effort each.

Recommendations
  Based  on the results of the project
summarized herein, it is recommended
that the EPA proceed with specific  im-
plementation plans and  a program to
develop the automated advisory system
to assist in the review of RCRA permit
applications as  soon  as  possible.
Specifically, it is recommended that the
implementation incorporate the follow-
ing:
• The integrated version of the  advi-
  sory system  should be evaluated in
  the first year of the implementation
  program and a  decision on system
  configuration should be made at  the
  beginning of the second year.
• Knowledge bases for assistance in re-
  viewing waste  analysis plans and
  synthetic membrane liner  selection,
  in checking the  completeness of  ap-
  plications, and  in  using the HELP
  model  should be developed in  the
  first year of the  program.
• A program to obtain feedback on sys-
  tem utility and system enhancements
  from permit applications reviewers
  should be established early.
• Field tests of prototype expert sys-
  tems in EPA Regional Offices should
  be initiated six months after develop-
  ment is started.
• Arrangements  for system mainte-
  nance and system performance mon-
  itoring should be completed in  the
  second year  of the program.
  The full report was submitted in fulfill-
ment of EPA Contract 68-02-3992 by the
Research Triangle Institute under  the
sponsorship of the U.S. Environmental
Protection Agency.
 Advisory System Modules
 Supervisory Module and
  Inference Engine
 Explanation Module and
  Report Generator
                 y    \
                 S/S/J1 }
                 "1   /
Expert System Library
  Synthetic Liner Design''
  Waste Analysis Plan'
  Dike Design and Construction
  Cover Systems2
  Soil Liners
  Leachate Collection Systems
  Facility Location Information

  Remaining (SelectedI Knowledge
  Bases

Job Know/edge Base
  Completeness Check
  Supervisory Functions

Analytical Model Library
  HELP
  Remaining (Selected) Models
 Field Test
 Deployment
 Maintenance
 'Knowledge acquisition partially complete.

 2Part of Closure Plans.

Figure 2.    Tentative implementation schedule.
                                         ^HI^H Separate Module Implementation
                                         Y///////A Integrated Advisory System

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