Environmental Technology
Verification Report
PRIVATE PALLET SECURITY SYSTEM, LLC,
MULTITRACK™ LAYERED TRACKING SYSTEMS
                Prepared by
                  Battelle

                Baneiie
               The Business of Innovation
           Under a cooperative agreement with


             U.S. Environmental Protection Agency


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                                       September 2009
Environmental Technology Verification
                  Report

   ETV Advanced Monitoring Systems Center

 PRIVATE PALLET SECURITY SYSTEMS, LLC.
    MULTITRACK™ LAYERED TRACKING SYSTEM
                      by
     Ryan James, Brian Boczek, Zachary Willenberg, Amy Dindal, Battelle
 Deborah Kopsick, Carlos Rincon, Michelle Henderson, and John McKernan, U.S. EPA

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                                         Notice
 The U.S. Environmental Protection Agency, through its Office of Research and Development,
funded and managed, or partially funded and collaborated in, the research described herein.  It
 has been subjected to the Agency's peer and administrative review and has been approved for
publication. Any opinions  expressed  in this report  are  those of the author (s) and do not
 necessarily reflect the views of the Agency, therefore, no official endorsement should be inferred.
Any mention  of trade  names or  commercial products does not  constitute  endorsement or
 recommendation for use.
                                           11

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                                      Foreword

The U.S. Environmental Protection Agency (EPA) is charged by Congress with protecting the
Nation's land, air, and water resources. Under a mandate of national environmental laws, the
Agency strives to formulate and implement actions leading to a compatible balance between
human activities and the ability of natural systems to support and nurture life.  To meet this
mandate, EPA's research program is providing data and technical support for solving
environmental problems today and building a science knowledge base necessary to manage our
ecological resources wisely, understand how pollutants affect our health, and prevent or reduce
environmental risks in the future.

The National Risk Management Research Laboratory (NRMRL) is the Agency's center for
investigation of technological and management approaches for preventing and reducing risks
from pollution that threaten human health and the environment.  The focus of the Laboratory's
research program is on methods and their cost-effectiveness for prevention and control of
pollution to air,  land, water, and subsurface resources; protection of water quality in public water
systems; remediation of contaminated sites, sediments and groundwater; prevention and control
of indoor air pollution; and restoration of ecosystems. NRMRL collaborates with both public
and private sector partners to foster technologies that reduce the cost of compliance and to
anticipate emerging problems. NRMRL's research provides solutions to environmental
problems by: developing and promoting technologies that protect and improve the environment;
advancing scientific and engineering information to support regulatory and policy decisions; and
providing the technical support and information transfer to ensure implementation of
environmental regulations and strategies at the national, state, and community levels.

This publication has been produced as part of the Laboratory's strategic long-term research plan.
It is published and made available by EPA's Office of Research and Development to assist the
user community and to link researchers with their clients.
                                         Sally Gutierrez, Director
                                         National Risk Management Research Laboratory
                                           in

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                                 Acknowledgments

The authors wish to acknowledge the contribution of the New Mexico Border Authority for
hosting this verification at the Santa Teresa Port of Entry (POE) and, in particular, the efforts of
Mr. Marco Herrara in providing his export expertise in support of this verification test. We
thank Dr. Barry Thatcher of BorderWriting, for supporting this verification test, but specifically
for his  coordination with the Mexican Customs officials  along with all other local participants.
Also, we acknowledge the cooperation of the New Mexico Department of Public  Safety in
providing read locations and Servicio de Transports Internacional y Local in providing a truck
and driver and Ivan Calzada of the Texas Transportation Institute.  Finally, we thank Ms. Debra
Tellez, Ms. Katrina Varner, and Mr. Israel Anderson of the U.S. EPA, Mr. Stephen Niemeyer of
the Texas Commission on Environmental Quality, and Mr. Jose Mario Sanchez Soledad,
Comision de Ecologia y Protection Civil, Gobierno Municipal De Juarez for their review of the
test/QA plan and/or this verification report.
                                          IV

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                                      Contents
                                                                                  Page

Foreword	iii

Acknowledgments	iv

List of Abbreviations	vii

Chapter 1 Background	1

Chapter 2 Technology Description	2

Chapters Test Design and Procedures	3
  3.1 Test Overview	3
  3.2 Experimental Design	4
      3.2.1 RFID Tags and HAZMAT Waste Containers	4
      3.2.2 Waste Container Configuration in the Semi-Trailer	4
      3.2.3 Meteorological and Shock Data	5
      3.2.4 Collision Test	6
      3.2.5  Truck Routes and Descriptions of Round Trips	6
      3.2.6 Route Deviation	10
  3.3 Qualitative Evaluation Parameters	10

Chapter 4 Quality Assurance/Quality Control	11
  4.1 Audits	11
      4.1.1  Technical Systems Audit	11
      4.1.2 Data Quality Audit	11
  4.2 QA/QC Reporting	11
  4.3 Data Review	12

Chapters Statistical Methods	13
  5.1 Accuracy	13
  5.2 Precision	13
  5.3 Influence of Confounding Factors	14

Chapter 6 Test Results	15
  6.1 Accuracy	15
  6.2 Precision	17
  6.3 Interference  of Other RFID Signals	17
  6.4 Influence of Confounding Factors	17
  6.5 Operational Factors	18

Chapter 7 Performance Summary	20

Chapters References	22

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                                        Figures

Figure 2-1. P2S2 RFID tag in tag housing	2
Figure 2-2. P2S2 communication module (Sentry)	2
Figure 3-1. RFID tag affixed to poly drum	4
Figure 3-2. Tightly-packed configuration	5
Figure 3-3. Loosely-packed configuration	5
Figure 3-4. Collision Tags	6
Figure 3-5. U.S. route used during testing (border area enlargement)	7
Figure 3-6. U.S. route used during testing	8
Figure 3-7. Mexico route used during testing (border area enlargement)	9
Figure 3-8. Mexico route used during testing	9
Figure 6-1. Screenshot from P2S2's mapping software	18
                                         Tables

Table 3-1. Summary of Round Trips	10
Table 6-1. Accuracy	16
Table 6-2. Container Identification Data Completeness	16
Table 6-3. Overall Accuracy ± Standard Deviation of Each RT	17
Table 6-4. Collision Test Results	17
Table 6-5. Accuracy Results by Container Type	18
Table 7-1. Accuracy, Precision, and Data Completeness	20
                                           VI

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                              List of Abbreviations

AMS      Advanced Monitoring Systems
P2S2      Private Pallet Security System, LLC
EPA       Environmental Protection Agency
ETV       Environmental Technology Verification
GPS       Global positioning system
GHz       Gigahertz
HAZMAT  Hazardous materials
LRB       Laboratory record book
MHz      Megahertz
Mph       Mile per hour
MX       Mexico
NMBA     New Mexico Border Authority
NMDPS    New Mexico Department of Public Safety
NRMRL    National Risk Management Research Laboratory
Poly       Polyethylene
POE       Port of Entry
QA        Quality assurance
QMP      Quality Management Plan
RFID      Radio-frequency identification
RT        Round Trip
SD        Standard  deviation
STIL      Service de Transporte Internacional y Local
TQAP     Test Quality Assurance Plan
U.S.       United States
                                        vn

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                                      Chapter 1
                                     Background


The U.S. Environmental Protection Agency (EPA) supports the Environmental Technology
Verification (ETV) Program to facilitate the deployment of innovative 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.

ETV works in partnership with recognized testing organizations; with stakeholder groups
consisting of buyers, vendor organizations, and permitters; and with the full participation of
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 or 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 EPA's National Risk Management Research Laboratory  (NRMRL) and its verification
organization partner, Battelle, operate the Advanced Monitoring Systems (AMS) Center under
ETV. The AMS Center evaluated the performance of the MultiTrack™ Layered Technology
System by Private Pallet Security Systems, LLC. (P2S2), a web-based real-time locating and
reporting system, in tracking hazardous materials (HAZMAT) being returned to the U.S. from
Mexico under terms of the La Paz Agreement. Under this agreement, all HAZMAT waste
generated by raw materials shipped into Mexico for use in foreign-owned factories (called
maquilas) must be shipped back to their country of origin. Mexico does not classify the returned
material as hazardous, but as a returned product, and  therefore does not submit a Notice of Intent
to the United States for the export of such HAZMAT waste. The current process makes it
difficult to develop an accurate accounting of HAZMAT waste  entering the United States from
the maquilas and does not provide for timely identification of shipments that do not reach  their
designated receiving facilities.  The lack of tracking of these wastes creates the possibility for
waste to be illegally abandoned. An enhanced tracking system that provides accurate, timely data
to regulatory officials would be beneficial in preventing this from occurring.  This verification
test evaluated the performance  of such tracking technologies.

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                                      Chapter 2
                              Technology Description
This verification report provides results for the verification testing of P2S2's MultiTrack™
Layered Tracking System (hereafter referred to as Multi Track).  Following is a description of the
MultiTrack technology, based on information provided by the vendor.

P2S2's MultiTrack is a hybrid, multi-functional network topology that enables fully automated
wireless identification, location, environment monitoring and real time tracking of HAZMAT
shipped throughout the world, providing information down to the item level.

 During this verification testing, MultiTrack
utilized active radio-frequency identification
(RFID) tag tracking coupled with P2S2's
communication module (referred to as the
Sentry). The system components included active
RFID tags shown in Figure 2-1, an antenna that
was attached to the inside of the trailer door, and
the Sentry which was connected to the antenna
and located in a box mounted to the external of
the trailer door, as shown in Figure 2-2.  The
RFID tags emit a radio frequency that is read
continuously by the antenna and stored by the
Sentry. This eliminated the need to install or pass
any fixed readers along the travel route.  Then,
approximately every five minutes, and any time
an alarm event occurs, the Sentry transmitted the
identified RFID tags and the type of the alert or
alarm, as well as the global positioning (GPS)
coordinates of the Sentry, to a central P2S2
database via cellular phone connection. Web-
based P2S2 software allows real-time mapping of
the movement of whatever is being tracked. The
P2S2 communication module is customizable
with a variety of communication, sensor and
power options.  Prior to the start of the
verification test, P2S2 setup the MultiTrack
according to their recommended configuration for
optimal performance.
Figure 2-1. P2S2 RFID tag in tag
            housing
Figure 2-2.  P2S2 communication
        module (Sentry)

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                                      Chapter 3
                            Test Design and Procedures
3.1 Test Overview
This verification test was conducted according to procedures specified in the Test/QA Plan for
Verification of Radio Frequency Identification (RFID) for Tracking Hazardous Waste Shipments
across International Border's^(TQAP) and adhered to the quality system defined in the ETV
AMS Center Quality Management Plan (QMP)(2). Battelle conducted this verification test with
support from the New Mexico Border Authority (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, and Servicio de
Transports Internacional y Local (STIL).

This verification 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. 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 (MX),
so two of the trucking routes did not cross into MX and two routes included crossing the border
into MX.  RFID tags were attached to various containers and loaded onto a truck at the U.S.
loading dock at the NMBA facility using a standard 53-foot semi-truck and trailer provided by
STIL, a local trucking company. Throughout the testing, the containers were arranged in the
trailer in either a tightly-packed or loosely-packed orientation. The MultiTrack system included
the RFID tags (attached to HAZMAT waste containers) and in-trailer antenna along with the
Sentry communication module attached to the exterior of the trailer door. The truck then left the
NMBA loading dock, drove a prescribed  route either solely  in the U.S.  or across the U.S. - MX
Border. RFID tag reads were recorded electronically throughout each truck route.

This verification test of the MultiTrack was conducted on March 24 and 26, 2009 at the NMBA
Santa Teresa facility and other field locations throughout the El Paso/Ciudad Juarez trade area.
The MultiTrack was verified by evaluating the following parameters:

    •   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 loading 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.

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       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 - ease of use, technology cost, user-friendliness of vendor software,
       troubleshooting/downtime, etc.
3.2 Experimental Design

3.2.1  RFID Tags and HAZMAT Waste Containers

At the beginning of each day of testing, verification test staff verified the function of 12 P2S2
RFID tags to be used as part of this verfication testing by measuring the frequency and the
effective radiated power of the tag using a Rhode and Schwartz FSH6 spectrum analyzer with a
435 Megahertz (MHz) antenna. This was done by placing all RFID tags into the trunk of an
automobile thereby isolating the signal emitted by each RFID tag from the spectrum analyzer.
Next, a single RFID tag was removed from the automobile trunk, the trunk was again closed, and
the single RFID tag was taken into the NMBA office building. The single RFID tag emitted
frequencies and the effective radiated power of each frequency was measured and recorded.
This process was repeated for all 12 P2S2 RFID tags and the four RFID tags used for the
collision test.

According to current shipping practices, most
of the HAZMAT entering MX from the U.S.
are contained in either poly or steel 55-gallon
drums, and much of the HAZMAT waste
returning from the maquila and entering the
U.S. is solid and packaged in one-cubic yard
corrugated boxes or as drummed liquids.
Accordingly, once the functioning of the
RFID tags had been confirmed, four RFID
tags were secured to poly 55-gallon drums,
four were secured to the steel 55-gallon
drums, and four were affixed to corrugated
cardboard boxes for a total of twelve
individual containers. One tag was affixed to
each individual container. Figure 3-1  presents
a photo of an RFID tag affixed to a poly
drum. In the interest of safety, no actual hazardous waste was transported during the verification
test.  Each poly and metal 55-gallon drum used in the verification testing was filled with tap
water and each corrugated box was filled with loosely folded cardboard.  RFID tags were
secured to the top of each poly and metal drum and to the side of each corrugated box using
Velcro tape.

3.2.2  Waste Container Configuration in the Semi-Trailer

Each round trip (RT) conducted in the U.S. was performed using a tightly-packed configuration
of the HAZMAT waste containers. Each RT into MX was performed using a loosely-packed
configuration.
                                           4
Figure 3-1.  RFID tag affixed to poly drum

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Each packaging configuration consisted of 12 individual containers. Two metal drums were
placed on a pallet and the drums were shrink-wrapped to secure the drums during transport. The
process was repeated for the poly drums as well.  Therefore, four pallets of drums were created;
two pallets of two metal drums each and two pallets of two poly drums each. The corrugated
boxes were not affixed to a pallet but placed directly on the floor of the trailer.  The corrugated
boxes and the pallets of drums were then positioned inside the truck trailer in a tightly-packed
configuration.  For the loosely-packed configuration, each pallet contained one of each kind of
drum. Figures 3-2 and 3-3 show diagrams of tightly packed and loosely packed container
configurations.
              Front of Truck
          O
          >
            papa
            nn
            nn
o
DD
C
Cl
           Rearof Truck

I   Pallet         £  55-gallon Metal Drum

  1 Cubic Yard     O  55-gallon Poly Drum
  Corrugated Box
       Figure 3-2. Tightly-packed
              configuration
                                                      Front of Truck
                                                       a
                                                      13
DC?
                                                                       o
                                                                       —
o
DO
C
                                                           Rcarof Truck

                                                I   Pallet         ^ 55-gallon Metal Drum

                                                  1 Cubic Yard     O 55-gallon Poly Drum
                                                  Corrugated Box
                                                Figure 3-3. Loosely-packed
                                                       configuration
Regardless of packing configuration, each corrugated box was positioned such that one RFID tag
faced each side of the trailer (i.e., one RFID tag faced the driver's side, the passenger's side, the
front, and the rear of the trailer).
3.2.3 Meteorological and Shock Data

After the palletized poly and metal 55-gallon drums and the corrugated boxes were loaded into
the trailer and positioned in the correct packaging configuration, a Shocklog™ RD 298 system
(Shocklog) was installed directly onto the floor of the trailer and a calibrated hot wire
anemometer (TSI Incorporated, VelociCalc 9555-P Multi-function Ventilation Meter), capable
of measuring temperature, barometric pressure, and relative humidity, was affixed to the
passenger's side of the trailer approximately two feet above the floor. At the end of each day of
verification testing, the electronic data generated and captured by the Shocklog and the
anemometer were transferred from the instrument to a computer by means of a portable drive.

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3.2.4 Collision Test

A collision test was performed during each RT run to evaluate the ability for the MultiTrack
system to discriminate the P2S2 RFID tags from other commercially available active RFID tags.
Battelle supplied four commercially available tags for collision testing; the collision tags were
active RFID tags (Wavetrend® TG801) at a frequency of 433 MHz, the same frequency at which
the MultiTrack system operated. The collision tags were affixed to a wooden block as shown in
Figure 3-4. At the beginning of the day of testing, the function of each collision tag was verified
separately by measuring the
frequency and  the effective radiated
power of the tags using the
spectrum analyzer.

A collision test was performed
during each verification test run at
the NMDPS truck inspection
facility. The truck would conduct
its first pass of the 25 and 15 miles
per hour (mph) read locations.  The
truck would then begin its second
pass and pass the 25 mph read
location. After passing the 25 mph
read location the second time, the
truck stopped,  the trailer was
opened, and the collision tags added
to one of the one-cubic yard
corrugated boxes. The trailer doors
were then  closed and the truck proceeded past the 15 mph read location and on to the NMBA
after which the collision tags were removed.
Figure 3-4.  Collision Tags
3.2.5  Truck Routes and Descriptions of Round Trips

The TQAP1 was written with the expectation that the same trucking route would be used
throughout the verification test and that the route would include crossing over in MX. However,
there was some difficulty in obtaining permission to cross the border into MX, so two of the RTs
were performed within the U.S. and when the proper permission was obtained, the other two RTs
were performed crossing the border into MX.  Also, the TQAP was written with the assumption
that the technologies to be evaluated would have external readers that would be set up at various
read points throughout the trucking route.  This was not the case for the MultiTrack. The
MultiTrack uses an antenna inside the trailer door  to receive the tag information. The antenna
was mounted on the inside door  of the trailer and the Sentry communication module on  the
outside of the door.  These features eliminated the need to install or pass any fixed readers along
the travel route. MultiTrack reported the presence and location (through the use of global
positioning tracking) of the identified tags at five minute intervals. However,  because the TQAP
was originally written  with the focus of external readers, specific read locations were still used to
guide the truck routes  and the speed that the truck  was traveling. Because the data were reported
approximately every five minutes, there was no guarantee that the RFID data would be collected

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exactly at the fixed read locations as defined in the TQAP. However, the routes the truck
followed encompassed "stop and go" driving as well as highway driving. Therefore, the fixed
read locations defined a route for the truck and the data were reported approximately every five
minutes, providing additional tag identification and location data throughout the RTs than
specified in the TQAP.  The two RTs performed in the U.S. and the two RTs including the
border crossing into MX are described below.

U.S. Trucking Route. The U.S. Trucking Route was selected to mimic, as much as possible, the
tag read locations presented in the TQAP and to challenge the MultiTrack system under the same
critical variables  and  similar test conditions specified in the TQAP.

The HAZMAT waste containers were loaded into the trailer and placed in the tightly-packed
configuration for both of the U.S. RTs.  The truck began all of the RTs (U.S. and MX) at the
NMBA facility.  One of the read locations (as planned for external readers) was located at the
exit to the NMBA facility.
Upon exit from the NMBA, the
truck travelled to the NMDPS
facility. Figure 3-5 shows the path
of the truck between the NMBA and
the NMDPS facility.  The total
distance between the two locations
was approximately 0.75 miles.
There were two read locations on the
driveway to the NMDPS facility.
The first location was designated as
a 25  mile per hour (mph) read point
and the second location was
designated a 15 mph read point. As
the truck approached both the 25
mph and 15 mph read points, the
speed at which the truck was
travelling was measured using a
Stalker Sport™ 24.15 Gigahertz
(GHz) Doppler radar gun. The truck
then  exited the NMDPS facility and
doubled back to make a second  pass.
After passing the 25 mph read point, the truck was stopped, the trailer doors opened, the contents
of the trailer inspected for any shifting of the load, and collision tags were added. The truck then
passed the 15 mph read point. After passing the 15 mph read location truck the collision tags
were removed. As was the case with the first pass of the truck through the NMDPS facility, the
speed at which the truck was travelling past the 25 mph and 15  mph read points was measured
using the radar gun.
                              - ' ....
                                         • li  •
Figure 3-5. U.S. route used during testing (border
               area enlargement)

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Figure 3-6. U.S. route used during testing
The truck then proceeded to the
Sunland Park Racetrack and Casino
parking lot (referred to as the
casino read location) as is shown in
Figure 3-6. This location was
selected because the route to the
casino (approximately 13 miles)
provided highway and city driving
and the parking lot at the casino
provided adequate space for the
truck to turnaround. From the
NMDPS, the truck travelled
northbound on Peter V. Domenici
Boulevard, east on Airport Road,
southeast on McNutt Road (NM-
273) and finally north on Sunland
Park Drive to the Sunland Park
Racetrack and Casino parking lot.
Upon arrival at the casino,  the truck
entered the parking lot and waited
for five minutes to allow adequate
time for an uplinked data report to P2S2's central server from the casino location.

The truck left the casino parking lot and proceeded northbound on Sunland Park Drive. The
truck next travelled northwest on Doniphan Road, west on Aircraft Road and south on Peter V.
Domenici Boulevard and then the truck returned to the NMBA facility. While the read locations
provided a framework for the route the truck traversed and the speed at which it travelled,
because the P2S2 system communicated the container identification and location approximately
every 5 minutes, regardless of location, the container identification took place continuously
throughout each RT.

Mexico Trucking Route.  The MX Route was selected to mimic, as closely as possible, the tag
reader locations presented in the TQAP and to challenge the MultiTrack system under the same
critical variables and similar test conditions specified in the TQAP, which included crossing the
border to evaluate an considerations regarding the technology in an actual border crossing.

The HAZMAT waste containers were loaded into the trailer and placed in the loosely-packed
configuration for both of the MX RTs. The read locations defining the MX route are shown in
Figure 3-7 and Figure 3-8.  As for each U.S. and MX RT, the truck began its route at the NMBA
facility. Upon exiting the NMBA, the truck travelled to the MX Jeronimo Port of Entry (POE)
and into MX. The truck made its way through the POE with slow "stop and go" driving as it
waited in a line of trucks and had to stop for various inspections.  After passing through the POE,
the truck proceeded for approximately 12 miles southbound  on the Samalayuca-El Oasis
Highway (Carratera Samalayuca-El Oasis).

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The third read location (referred to
as MX Turnaround) on the MX
Route was located 0.6 miles north
of the intersection of the
Samalayuca-El Oasis Highway and
MX Highway 2 After passing this
read location, the truck performed a
U-turn and proceeded northbound
on the Samalayuca-El Oasis
Highway, passing back into the
U.S. through the Santa Teresa POE
and U.S.  Customs.

After passing through U.S.
Customs, the truck then proceeded
to the NMDPS facility, following
the same  route as had been included
for the U.S RTs. The truck passed a
25 mph read point and a 15 mph
read point and then doubled back to
pass them again, with the collision
tags added before the second pass by
the 15 mph read point.  As was the
case during the U.S. RTs, the speed
at which the truck was travelling
past the 25 mph and 15 mph read
location was measured using a radar
gun.  The truck then proceeded back
to the NMBA read location.  Each of
the four RTs are summarized in
Table 3-1.
                       EOiita* OEEraestBaa <®§ ratto raGoaft
Figure 3-7. Mexico route used during testing
         (border area enlargement)
                                       Figure 3-8. Mexico route used during testing

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Table 3-1. Summary of Round Trips
Truck Route
RT 1 U.S.
RT2U.S.
RT3MX
RT4MX
Read Locations of Round Trips
Began at NMBA, NMDPS Facility (25 and
15 mph, collision test), casino, completed
at NMBA
Began at NMBA, NMDPS Facility (25 and
15 mph, collision test), casino, completed
at NMBA
Began at NMBA, Mexico Port of Entry, MX
Turnaround, NMDPS Facility (25 and 15
mph, collision test), completed at NMBA
Began at NMBA, MX Port of Entry, MX
Turnaround, NMDPS Facility (25 and 15
mph, collision test), completed at NMBA
Information about RT
Tightly packed configuration
Tightly packed configuration
Loosely packed configuration, uplinked
data missing for approximately half of the
RT
Loosely packed configuration
3.2.6 Route Deviation

The MultiTrack had an optional feature to provide indication when the RFID tags had traveled
outside a pre-programmed route. To test this feature, during each RT, the P2S2 staff constructed
an "electronic fence" that simulated the truck leaving the pre-programmed route.  When the truck
crossed the location of the electronic fence, an alert was sent to the central database and
documented with the rest of the RFID and location data.  Alerts were also sent to email and cell
phones via text messaging. The test evaluated whether or not the proper alert for such a route
deviation would be made.
3.3 Qualitative Evaluation Parameters

Operational factors such as ease of use, technology cost, user-friendliness of vendor software,
and troubleshooting/downtime, etc. documented based on observations by Battelle, Border
Writing, and U.S. EPA staff.
                                          10

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                                      Chapter 4
                        Quality Assurance/Quality Control


QA/QC procedures were performed in accordance with the TQAP for this verification test(1) and
the QMP for the AMS Center*-2-*. As noted throughout Chapter 3, there were some deviations
from the TQAP, but the work was performed as described in the previous sections. None of the
deviations from the test/QA plan resulted in any adverse impacts on the quality of the data
produced by this verification test. All deviations were reviewed with the EPA ETV AMS Center
Project Officer and EPA ETV AMS Center Quality Manager.  QA/QC procedures and results are
described in the following subchapters.
4.1 Audits

Two types of audits were performed during the verification test; a technical systems audit (TSA)
of the verification test procedures, and a data quality audit. Because of the nature of RFID
measurements, a performance evaluation audit, as is usually performed to confirm the accuracy
of the reference method, was not applicable for this verification test. Audit procedures for the
TSA and the data quality audit are described further below.

4.1.1  Technical Systems Audit

The Battelle AMS Center Quality Manager performed a TSA during the test to ensure that the
verification test was performed in accordance with the TQAP for this verification test*-1-* and the
                       //^\  	  	                              	
QMP for the AMS Center .  The TSA noted no adverse findings. A TSA report was prepared,
and a copy was distributed to the EPA AMS Center Quality Manager.  In addition, the EPA
AMS Center Quality Manager was also present during a portion of the verification test and also
performed a separate TSA.

4.1.2  Data Quality Audit

At least 10% of the data acquired during the verification test were audited. The data were traced
from the initial acquisition, through reduction and statistical analysis, to final reporting to ensure
the integrity of the reported results. All calculations performed on the  data undergoing the audit
were checked.
4.2 QA/QC Reporting

Each audit was documented in accordance with Sections 3.3.4 and 3.3.5 of the QMP for the
AMS Center.(2)  Once the audit reports were prepared, the Battelle Verification Test Coordinator
ensured that a response was provided for each adverse finding or potential problem and

                                          11

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implemented any necessary follow-up corrective action. The Battelle Quality Manager ensured
that follow-up corrective action was taken. The results of the TSA were submitted to the EPA.
4.3 Data Review

Records generated in the verification test received a one-over-one review before these records
were used to calculate, evaluate, or report verification results. Data were reviewed by a Battelle
technical staff member involved in the verification test. The person performing the review added
his/her initials and the date to a hard copy of the record being reviewed.
                                           12

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                                      Chapter 5
                                 Statistical Methods
The statistical methods used to evaluate the quantitative performance factors listed in Section 3.2
are presented in this chapter. Qualitative observations were also used to evaluate verification test
data.
5.1 Accuracy

A primary objective for this verification test was to determine the accuracy of P2S2's
MultiTrack   Layered Tracking System performance with reading tags under critical variables
and test conditions.  Accuracy is a measure of the agreement between a measured value and the
"true" value.  For this verification, accuracy was determined as a percentage according to the
following formula:

                                   A = (l-E/N)x 100                               (1)

where A is the percent accuracy of the RFID system, E is the total number of tags that were not
properly recognized, and N is the total number of tagged HAZMAT containers.  The accuracy of
the system was determined for each read point and packaging type and throughout the entire trip.
The highest percent accuracy possible is 100%.
5.2  Precision

Precision is a measure of agreement among repeated measurement.  The precision of tag reads
completed by the MultiTrack was determined by calculating the SD of the accuracy at all
possible read locations. The SD of the accuracy measurements was calculated using the
following formula:
where, Sx,i is the SD of all accuracy measurements in verification test run /', n is the total number
of possible read events in verification test run /', A^ is the percent accuracy of the RFID system
reader for read event k during verification test run /', and A, is the overall arithmetic average
percent accuracy of the RFID system during verification test run /'.
                                           13

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5.3  Influence of Confounding Factors

The influence of the different container types on the accuracy of container identification was
evaluated by calculating the accuracy in each container during each RT.  Then a paired t-test was
performed to determine if significant differences existed between the accuracy of the
identification of steel drums, poly drums, and cardboard boxes.  Other possible confounding
factors included meteorological and environmental conditions. These data were reviewed
qualitatively in attempt to identify possible correlations where statistical approaches should be
considered.
                                           14

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                                       Chapter 6
                                     Test Results
As mentioned previously, this verification test included both quantitative and qualitative
evaluations. The quantitative evaluation was conducted to assess the accuracy and precision of
the MultiTrack, as well as test the influence of confounding factors and its ability to discriminate
the HAZMAT waste tags from other commercially-available active tags. The qualitative
evaluation was performed to document the operational aspects of P2S2's system when it was
used during verification testing. The following sections provide the results of the quantitative
and qualitative evaluations.
6.1 Accuracy

This configuration of the MultiTrack technology included an RFID antenna that was attached to
the inside of the back door of the trailer.  That antenna was connected to the Sentry
communication module that was attached to the outside of the trailer and served as the
communication link by transmitting the collected data via cellular communication to a P2S2
computer server approximately once every five minutes during each RT. Because the tags were
being read at a regular frequency, regardless of location, it eliminated the need to pass by an
external reader at a single location.  Because the  fixed read locations defined the route of the
truck, container identification results from several individual read locations are presented,
indicating the accuracy of the container identification at the times that the truck was at the
various read locations.

Table 6-1 presents the accuracy results for the MultiTrack system and Table 6-2 gives the data
completeness for each RT. Accuracy is defined as the percentage of correct container
identifications out of the total possible identifications. Data completeness is defined as the
fraction of the total duration of the RT that the continuous data uplink was occurring (less than
six minutes between data uplinks).  The accuracy at the various read locations during RT 1 was
either 92% (corresponding to one missed tag) or  100%, and during the entire trip, the overall
accuracy was 322 correct container identifications out of 324 possible identifications for an
overall accuracy of 99%. In addition, the data completeness for this RT was 100% as data were
collected throughout the RT. The accuracy at the various read locations during RT 2 was also
either 92% or 100%.  During the round trip, the overall accuracy was 99% with 355 correct
container identifications out of a possible 360. As had been the case for RT 1, the data
completeness for this RT was 100%.

RTs 3 and 4 crossed the U.S.-MX border into MX, travelled approximately 12 miles, turned
around, returned to the U.S., followed the route through the NMDPS facility that dictated 25 and
15 mph read locations, and finished at the starting location of the NMBA. During RTs 3 and 4

                                           15

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Table 6-1. Accuracy
Round Trip Number
Truck Route
Packaging Config.
Read Locations
NMBA exit
MXPOE
NM Casino
MX Turnaround
NMDPS
25 mph pass
15 mph pass
25 mph pass
15 mph pass
(collision test)
NMBA entrance
Overall
RT1
US
Tight
RT2
US
Tight
RT3
MX
Loose
RT4
MX
Loose

100% (12/1 2)
(1)
92% (11/1 2)
(1)
92% (11/1 2)
(1)
100% (12/12)
(1)
100% (12/12)
100% (12/12)
(1)
100% (12/12)
100% (12/1 2)
100% (12/1 2)
(1)
100% (12/1 2)

100% (12/1 2)
100% (12/1 2)
100% (12/1 2)
92% (11/1 2)
100% (12/1 2)
99% (322/324)
100% (12/12)
100% (12/12)
100% (12/12)
100% (12/1 2)
100% (12/12)
99% (355/360)
100% (12/12)
100% (12/12)
100% (12/12)
100% (12/1 2)
100% (12/12)
100% (480/480)
100% (12/1 2)
100% (12/1 2)
100% (12/1 2)
100% (12/1 2)
100% (12/1 2)
100% (324/324)
   (1)  Read location not applicable for this RT
Table 6-2. Container Identification Data Completeness
Round Trip Number
Truck Route
Elapsed Time (min)
of route
Duration of
continuous data
uplinks (min)
Data completeness
RT1
US
107
107
100%
RT2
US
120
120
100%
RT3
MX
193
159
82%
RT4
MX
133
99
74%
there was one 34 minute time period during which container identification data were not
collected.  These gaps in data both occurred in MX as the truck returned from the MX
turnaround point.  According to P2S2, both of these gaps in data were caused by the lack of
cellular phone coverage during those time periods.  In both cases, the GPS tracking data were
recorded (stored, but not transmitted) approximately every five minutes during the time period
with missing data and then transmitted when the cellular connection was regained.  Over each 34
minute period, six data transmissions had been stored and then were transmitted upon regaining
connection.  No container identification data were collected during these time periods. P2S2
explained that the MultiTrack system is also capable of storing the container identification data
and then transmitting it along with the GPS information when the cellular coverage was
regained. However, this feature had not been enabled during the verification test. Overall, the
data completeness for the container identification during RTs 3 and 4 was 82% and 74%,
respectively.  Since the GPS data was stored when cellular phone service was unavailable, GPS
data completeness was 100%.

The accuracy at the various read locations during RTs 3 and 4 was consistently 100% throughout
the RTs. In addition, throughout the times during each of these RTs that container identification
data was collected, there were no misidentified containers for 100% accuracy. For RT 3 there
were 480 correct container identifications and for RT 4, 324 correct container identifications.
                                           16

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6.2 Precision

The precision, or repeatability, of the RFID accuracy data were determined as described in
Section 5.2 and is given in Table 6-3 along with the overall accuracy for each RT.

Table 6-3. Overall Accuracy + Standard Deviation of Each RT
 Truck Route   Accuracy + SD	
 RT1-US       99%+2%
 RT2-US       99% + 3%
 RT3-MX       100% + 0%
 RT4-MX       100% + 0%
The SDs were 2% and 3% for RTs 1 and 2 and 0% (meaning all individual data reports generated
consistent results) for RTs 3 and 4.
6.3 Interference of Other RFID Signals

The collision test was performed as described in Section 3.2.4 by placing four active RFID tags
into the trailer along with the containers that were tagged with the P2S2 RFID tags. Thereafter,
the truck passed the second 15 mph read location at the NMDPS facility and continued onto the
NMBA with the collision tags.  The data corresponding to that time period are shown in Table 6-
4. Overall, three out of the four available data sets resulted in 100% accuracy and one had 92%
accuracy. Prevention of all or most reads from taking place would have indicated a significant
interference. While difficult to determine conclusively with this small data set, these results
were similar to those presented in Table 6-1, suggesting that there was little or no negative
impact from the presence of four additional RFID tags.
Table 6-4. Collision Test Results
Truck Route
RT1-US
RT2-US
RT3-MX
RT4-MX
Accuracy (Identified
Tags/Total Tags)
92% (11/1 2)
100% (12/1 2)
100% (12/1 2)
100% (12/1 2)
6.4 Influence of Confounding Factors

Container type and packaging configuration. The RFID tags were placed on three different
types of containers during the round trips.  The accuracy results are presented in Table 6-5 by
container type. The only container type that had data misidentified by the system was the poly
drums. Accuracies near 100% (seven of out a total possible 684 during the RT1 and RT2 tests),
suggest that confounding factors were not an issue during this evaluation.

Meteorological and other environmental conditions. Throughout the two days of testing, the
temperature inside the truck ranged from 13.3 to 28.5 degrees Celsius (°C).  The relative
humidity ranged  from 14% to 20% and the barometric pressure ranged from 25.4 to 26.1 inches
of mercury (in Hg).  Upon a qualitative review of the accuracy data, meteorological conditions
did not appear to impact the results, so no statistical analyses were performed. Similarly, there

                                           17

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Table 6-5. Accuracy Results by Container Type (in percent)
Truck Route
RT1
RT2
RT3
RT4
Steel Drum
100
100
100
100
Poly Drum
98
96
100
100
Cardboard Box
100
100
100
100
was no observable correlation between the Shocklog data collected during each RT and the
accuracy results, so no statistical analyses were performed.

                                            3? P ¥& D Sh
                                               0000000000000*9
6.5 Operational Factors

The verification staff found that the MultiTrack system was easy to use. P2S2 staff set up the in-
trailer antenna and the external Sentry communication module and assisted the verification staff
in the application of the RFID tags. Once technology setup was complete, there was nothing
more that had to be done to operate the MultiTrack system. As implemented during this test, the
MultiTrack system required the communication module to be mounted on the outside of the
trailer. If implemented this way, it could call attention to the trailer as one that carried valuable
goods.

The software that P2S2 uses to handle the data collected by the uplinked data connection is web-
based and offers a number of utilities that were used during the verification test.  One optional
feature that was tested was the ability for the software to provide an alert when the truck crossed
an "electronic fence" placed along the planned truck route.  This was evaluated by designating
M.^.tii!— .  .......... .. .......... ...... ......... _ _  the U. S . and MX
                                                                       planned truck route
                                                                       (with destinations)
                                                                       in the system, and
                                                                       setting the alarm to
                                                                       indicate if the truck
                                                                       deviated from the
                                                                       planned route, and
                                                                       when the truck
                                                                       arrived at the
                                                                       destination. The
                                                                       electronic fence
                                                                       was identified as  a
                                                                       "geo-fence or route
                                                                       builder" which
                                                                       provided a detailed
                                                                       visual track on the
                                                                       mapping web page.
                                                                       An example of a
                                                                       geo-fence location
                                                                       is shown in Figure
                                                                       6-1 by a large
                                                                       green ring.  The
                                                                       path of the truck is
                                                                       shown by solid
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                                           18

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green circles as it starting at the NMBA travelling to the casino and then returning. Alarms were
sent to the verification staff by text message and email in real-time as the truck entered or exited
a geo-fence location. The P2S2 staff operated the software so no hands-on evaluation of its user-
friendliness was performed.

P2S2 RFID tags can be purchased at a price of $41 each. P2S2 anticipates that cost of the tags
will include the cost of the truck communication module, the cell service and the relational
database management for the hauler and disposal site. The cost to gain access to the database is
based on a 36 month contract and currently ranges from $135-$150 per month per wireless
device (e.g., the one Sentry communication module attached to the back of the trailer which
would be compatible with as many RFID tags as necessary).
                                           19

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                                      Chapter 7
                               Performance Summary
Accuracy and precision. Four RTs were performed using the Multi Track system. Table 7-1
summarizes the accuracy, precision, and data completeness of the MultiTrack system.

Table 7-1.  Accuracy, Precision, and Data Completeness
Round Trip
RT1-US
RT2-US
RT3-MX
RT4-MX
Accuracy (Correct IDs/Total
Possible) + SD
99% (322/324) + 2%
99% (355/360) + 3%
100% (480/480) + 0%
100% (324/324) + 0%
Data Completeness
100%
100%
82%
74%
Across the four round trips, there was a possibility of 1,488 container identifications and the
MultiTrack system made 1,481 of those identifications correctly for an overall accuracy of
99.5%.

As discussed in Section 6.1, the two MX round trips included 34 minute periods that the truck
was apparently out of the required cellular phone coverage area. During this time, the GPS
tracking data were stored and transmitted upon regaining adequate cellular coverage;  however,
the feature that would have allowed for the MultiTrack system to store and report the container
identification information along with the GPS data were not enabled during the verification test.
Therefore, the  container identification information was not documented during this timeframe
which is indicated by the data completeness percentages of less than 100% for RTs 3  and 4.

Interference with other RFID signals.  The collision test was performed as described in Section
3.2.4 by placing four RFID tags into the trailer along with the containers that were tagged with
the P2S2 RFID tags.  Three out of the four collision test data sets resulted in 100% accuracy and
one had 92% accuracy.

Influence of confounding factors. The influence of container type and environmental
conditions such as meteorological and shock conditions was considered as a possible factor in
MultiTrack performance.  However, accuracies near 100% for container identifications suggest
that confounding factors were not an issue during this evaluation.

Operational factors.  The verification staff found that the MultiTrack system was easy to use.
P2S2 staff set up the in-trailer antenna and the external Sentry communication module and
assisted the verification staff in the application of the RFID tags.  Once technology setup was
complete, there was nothing more that had to be done to operate the MultiTrack system. As

                                           20

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implemented during this test, the MultiTrack system required the communication module to be
mounted on the outside of the trailer.  If implemented this way, it could call attention to the
trailer as one that carried valuable goods.

The software that P2S2 uses to handle the data collected by the uplinked data connection is web-
based and offers a number of utilities that were used during the verification test. One optional
feature that was tested was the ability for the software to provide an alert when the truck crossed
an "electronic fence" placed along the planned truck route. This was evaluated by designating
the U.S. and MX planned truck route (with destinations) in the system, and setting the alarm to
indicate if the truck deviated from the planned route, and when the truck arrived at the
destination.  The P2S2 staff operated the  software so no hands-on evaluation of its user-
friendliness was performed.

P2S2 RFID tags can be purchased at a price  of $41 each. P2S2 anticipates that cost of the tags
will include the cost of the truck communication unit, the cell  service and the relational database
management for the hauler and disposal site.  The cost to gain access to the database is based on
a 36 month contract and currently ranges from $135-$150 per month per wireless device (e.g.,
the one Sentry communication module attached to the back of the trailer which would be
compatible with as many RFID tags as necessary).
                                           21

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                                    Chapter 8
                                    References
1.  Test/QA Plan for Test/QA Plan for Verification of Radio Frequency Identification (RFID)for
   Tracking Hazardous Waste Shipments across International Borders, Battelle, Columbus,
   Ohio, March 23, 2009.

2.  Quality Management Plan for the ETV Advanced Monitoring Systems Center, Version 7.0,
   U.S. EPA Environmental Technology Verification Program, Battelle, Columbus, Ohio,
   November 2008.
                                         22

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