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. ------- 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 ------- 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. ------- 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 ------- |