THE ENVIRONMENTAL TECHNOLOGY VERIFICATION
                                        PROGRAM
        U.S. Environmental Protection Agency
                                                                      Batteiie
                                                                     Business of Innovation
                     ETV Joint Verification Statement
      TECHNOLOGY TYPE:   RADIO FREQUENCY IDENTIFICATION

      APPLICATION:          TRACKING HAZARDOUS WASTE SHIPMENTS
                                ACROSS INTERNATIONAL BORDERS

      TECHNOLOGY NAME:  PANASEC MOBILE PERSONNEL AND ASSET
                                VISIBILITY SYSTEM

      COMPANY:              AVANTE International Technology, Inc.

      ADDRESS:               70 Washington Road         PHONE: 609-799-8896 x 121
                                Princeton Junction, NJ 08550 FAX:   609-799-9308

      WEB SITE:               www.avantetech.com
      E-MAIL:                 bjakubovic@aitechnology.com
The U.S. Environmental Protection Agency (EPA) has established the Environmental Technology Verification
(ETV) Program to facilitate the deployment of innovative or improved environmental technologies through
performance verification and dissemination of information. The goal of the ETV Program is to further
environmental protection by accelerating the acceptance and use of improved and cost-effective technologies.
ETV seeks to achieve this goal by providing high-quality, peer-reviewed data on technology performance to
those involved in the design, distribution, financing, permitting, purchase, and use of environmental
technologies. Information and ETV documents are available at www.epa.gov/etv.

ETV works in partnership with recognized standards and testing organizations, with stakeholder groups
(consisting of buyers, vendor organizations, and permitters), and with individual technology developers. The
program evaluates the performance of innovative technologies by developing test plans that are responsive to
the needs of stakeholders, conducting field and laboratory tests (as appropriate), collecting and analyzing data,
and preparing peer-reviewed reports. All evaluations are conducted in accordance with rigorous quality
assurance (QA) protocols to ensure that data of known and adequate quality are generated and that the results
are defensible.

The Advanced Monitoring Systems (AMS) Center, one of six verification centers under ETV, is operated by
Batteiie in cooperation with EPA's National Risk Management Research Laboratory. The AMS Center
evaluated the performance of a system for tracking hazardous material (HAZMAT) waste shipments across
international borders using radio frequency identification (RFID). This verification statement provides a
summary of the test results for AVANTE International Inc.'s PanaSec Mobile Personnel and Asset Visibility
System (PAVS).

-------
VERIFICATION TEST DESCRIPTION

This verification test was conducted from March 24-26, 2009 at the New Mexico Border Authority (NMBA)
Santa Teresa facility and other field locations throughout the El Paso/Ciudad Juarez area. Battelle coordinated
this verification test with support from the NMBA, New Mexico Department of Public Safety (NMDPS), Texas
Transportation Institute, U.S. EPA Region 6 El Paso Border Office, U.S. EPA Office of Enforcement and
Compliance Assurance, BorderWriting (a New Mexico company that coordinated participation of the local
collaborators prior to the ETV test), and Servicio de Transports Internacional y Local (STIL). This test simulated
shipments of HAZMAT waste contained in polyethylene (poly) drums, metal drums, and corrugated boxes
through routine land transportation routes and across international ports of entry in the El Paso/Ciudad Juarez
trade area.  RFID tags were attached to four of each container type for a total of 12 containers which were loaded
onto a standard 53-foot semi-truck and trailer at the NMBA facility's U.S. loading dock. Throughout testing, the
12 containers were arranged in the trailer in either a tight-packed or loose-packed orientation.

Originally, this ETV test was planned with the expectation that all of the trucking routes would include border
crossings. However, due to concern of local authorities related to the violence in Ciudad Juarez during the test,
there were some difficulties in obtaining permission to cross the border into Mexico, so two of the trucking routes
did not cross into Mexico, and two routes included crossing the border into Mexico. Prior to embarking on each
round trip (RT), an external reader was situated  on a stand at 90° with respect to the road with the stand placed
four feet from the side of the front bumper.  RFID tag reads were made at distances of 5, 15, 30, 50, and 70 feet
from the front bumper of the stationary truck by moving the external reader straight forward from the initial
placement of the reader. For the two U.S. RTs, the truck left the NMBA loading dock, passed an RFID reader
location in the  driveway of the NMBA, and 15-  and 25-mile-per-hour (mph) read locations were performed in the
driveway of the NMDPS truck inspection facility.  Subsequently, the truck was driven to a casino parking lot
where the truck passed an additional RFID reader location before returning to the NMBA loading dock. As part
of the two Mexico RTs, the truck followed a similar route except that instead of including the casino, it travelled
through the Mexico  Port of Entry and onto a turn around point in Mexico before returning to the U.S. The RFID
tag reads were  recorded electronically throughout each truck route.

A collision test was  performed during each RT to evaluate the  ability of the  PAVS to discriminate between the
AVANTE RFID tags and other commercially available active RFID tags.  Battelle supplied four commercially
available tags for collision testing (Wavetrend® TG801) at a frequency of 433 MHz, the  same frequency at which
the PAVS operated.  The collision tags were affixed to a wooden block and  placed in the truck before it travelled
by the second 15 mph read location.

The key evaluation parameters included:

•   Accuracy - proper identification of the tagged containers at various locations, at various truck speeds, on
    corrugated boxes or steel and poly 55-gallon drums, and in tightly packed and loosely packed configurations.
    Specifically, proper identification is defined as the retrieval of all information available about the tagged item
    according to the vendor's standard procedures.
•   Precision - standard deviation (SD) of percent accuracy RFID tag read results.
•   Interference of other RFID signals (collision test) - ability to discriminate the tags on the HAZMAT waste
    containers  from  other commercially-available  RFID tags.
•   Influence of confounding factors - container type, packing configuration and placement of tags/containers,
    environmental conditions, and internal trailer conditions.
•   Operational factors - such as ease of use, technology cost, user-friendliness of vendor software,
    troubleshooting, and downtime.

QA oversight of verification testing was provided by Battelle and EPA. Battelle and EPA QA staff conducted
technical systems  audits of the field testing and Battelle QA staff conducted a data quality audit of at least 10% of
the test data. This verification statement, the full report on which it is based, and the test/QA plan for this
verification test are all available at www.epa.gov/etv/centers/centerl.html.

-------
TECHNOLOGY DESCRIPTION

AVANTE's PAYS system included the RFID tags (attached to HAZMAT waste containers) and readers
(roadside external or an in-truck reader referred to as the Relayer that resided in the cab of the truck and
uplinked data to a central server in near real-time). The uplinked configuration is a HAZMAT transportation
tracking system and solution that incorporates patented RFID technologies coupled with global positioning
system (GPS)-general packet radio service -cell phone communication to assist HAZMAT transportation
security. The AVANTE data center server stores all transit and condition data to provide real-time tracking of
the HAZMAT via web-based software.

Each container of HAZMAT is individually tagged with an active ZONER™ tag.  The identity of each
                                      J  OO                            O           J
container is linked to the active tag identification. During verification testing, PAYS used two different
methods for RFID tag reading and communication: (1)  external readers and (2) an uplinked system. The
external readers are placed at fixed locations and only collected RFID data when the truck is driven past the
readers whereas the uplinked system with the reader, or Relayer, located in the cab of the truck, collects RFID
data and uplinks it to a central server approximately every minute.

VERIFICATION RESULTS

Accuracy and precision. The table below summarizes the accuracy and precision of the PAYS.

      Truck                External Reader                          Uplinked Data
      Route	(Identified Tags/Total Tags)±SD	(Identified Tags/Total Tags)±SD
      RT1 -US     94% (248/264) ± 6%	(1)	
      RT2-US     93% (211/228) ± 10%	67% (233/348) ± 32%	
      RT3-MX    86% (166/192) ±25%	89% (1,594/1,786) ± 15%	
      RT4-MX    (1)	95% (804-850) ± 7%	
      (1)   Read location not applicable for this RT

The external readers generated container identification accuracies that were above 90% and had SDs of 10% or
less for RTs 1 and 2.  RT 3 resulted in a lower overall accuracy and a higher SD. However, there were two read
locations as part of RT 3 that resulted in less than 35% accurate results, thus impacting the overall accuracy for
that RT. All of the other read locations for that RT had greater than 83% accuracy.

The uplinked configuration for RTs 2, 3, and 4 generated accuracies of 67%, 89%, and 95%, respectively. Data
were only collected for the first 40 minutes for RT 2. The frequency of missed reads increased throughout that
time period. The results from RTs 3 and 4 show that data were collected more than 80% of the time.  Apparently,
the time periods during which data were not collected were due to inadequate cell  phone  coverage, preventing the
transmittal and storage of the tag identification and GPS tracking data.

Interference with other RFID signals. Three out of the five collision test data sets resulted in 100% accuracy,
one had 92% accuracy, and one had 75% accuracy.  While difficult to determine conclusively with this small data
set, these results were similar to the non-collision test results in that some non-collision test read locations
resulted in accuracy percentages of 75%, 92%, and 100%.  These similarities, while not a quantitative evaluation,
suggest that the presence of the collision tags did not negatively affect the accuracy results.

Influence of confounding factors. The influence of container type was quantitatively  considered as a possible
factor in PAYS performance. A paired t-test was performed on the container identification accuracies as a
function of container type and no significant differences were determined between the container types. In
addition, there was no indication that environmental conditions during the testing significantly impacted any of
the results.  However, one tag was wetted by water splashed from a container during a RT.  This tag was missed
at a higher rate compared to other tags. High winds caused sandstorm conditions during the testing which caused
difficulty in reading the memory cards used for data collection on the external readers.  Instead of using the
memory card, the data were  downloaded using an ethernet port.

-------
Operational factors.  Three RTs were performed using the external reader and uplinked configurations of the
PAYS system. The external readers were used during the first two RTs that were performed within the U.S. and
the first RT into MX.  Prior to RT 3, AVANTE performed a firmware update to their software to ensure the
uplinked system worked properly. That update did not accommodate simultaneous operation with the external
reader configuration. The uplinked system was used for all four RTs, but had higher levels of data completeness
during RTs 3 and 4. No uplinked data were collected during RT 1 and data from 63% of RT 2 were not collected
due to gaps in cell phone coverage required for data transmission.

AVANTE staff set up the external readers and assisted with the application of the RFID tags to the HAZMAT
waste containers.  The ease  of use of the Mobile PAYS was notable as  setup could be quickly accomplished by
powering the system through the dashboard 12-volt power outlet and positioning of two small antennae inside the
truck's cab.

The PAYS technology had a decreased level of data completeness for the uplinking system due to blocks of
missing data during the verification test.  The reason for these missing blocks were not fully known for RTs  1 and
2, and for RTs 3 and 4, the gaps in data collection were due to lack of cell phone coverage. During RTs land 2,
the loss of cell phone coverage took place in the U.S.,  during RT 3 the loss of cell phone coverage took place on
both sides of the border near the MX POE on the way  back in to the U.S., and during RT 4, the loss of coverage
took place in MX on the way to the turnaround point.  During RTs 1 and 2, the transmission of tag identification
data did not restart when the truck re-entered an area with adequate cell phone coverage. Prior to RT 3,
AVANTE was able to make a change to the PAYS firmware that allowed for this to take place during RTs 3 and
4. This update did not accommodate simultaneous operation with the external reader configuration so the
external readers were not used for RT 4.  In addition, following RT 1, AVANTE staff had to repair a faulty GPS
receiver within the Relayer. Please see the full ETV report for Avante's explanation of performance and
technology modifications they have taken to address the gaps in data collection.

The uplinked configuration  of the AVANTE PAVS can be purchased as a service at a current price of
$1/day/vehicle which includes the Relayer, one driver's identification badge with Panic Button, and two
RFID tags for cargo or wall mount. The price is based on a two-year contract, with a $200 security deposit
refundable at lease termination. The price includes the utilities described above (i.e., route deviation, driver
location alerts, panic button functionality, text message alerts, etc.). Additional RFID tags are available for
purchase at $25 - $32 depending on quantity.
original signed by Lisa McCaulev
9/24/09
Lisa McCauley                         Date
Operations Manager
Chemical, Environmental, and Materials Operations
National Security Global Business
Battelle
original signed by Sally Gutierrez
9/29/09
                                                        Date
Sally Gutierrez
Director
National Risk Management Research Laboratory
Office of Research and Development
U.S. Environmental Protection Agency
     NOTICE: ETV verifications are based on an evaluation of technology performance under specific,
     predetermined criteria and the appropriate quality assurance procedures. EPA and Battelle make no expressed or
     implied warranties as to the performance of the technology and do not certify that a technology will always
     operate as verified. The end user is solely responsible for complying with any and all applicable federal, state,
     and local requirements. Mention of commercial product names does not imply endorsement.

-------