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: MULTITRACK™ LAYERED TRACKING SYSTEM

      COMPANY:              Private Pallet Security System, LLC

      ADDRESS:               4320 Winfield Road  Suite 200    PHONE: 630.836.8525
                                Warrenville, IL 60555           FAX : 630.559.8899

      WEB SITE:               www.p2s211c.com
      E-MAIL:                 jsamony@ p2s211c.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 Private Pallet Security System's (P2S2) MultiTracktm Layered Tracking System
(MultiTrack).

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.  Batteiie coordinated

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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, Border Writing (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 hazardous 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 tightly-packed or loosely-packed configuration.

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. For the two U.S. RTs, the
truck left the NMBA loading dock, passed a RFID read location in the driveway of the NMBA and 15 and 25
miles per hour (mph) read locations 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 read 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 turnaround 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  MultiTrack to discriminate between
the P2S2 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 MultiTrack system 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 hazardous 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 available at www.epa.gov/etv/centers/centerl.html.

TECHNOLOGY DESCRIPTION

The MultiTrack system consisted of RFID tags (attached to HAZMAT waste containers) coupled with P2S2's
communication module (referred to as the  Sentry).  The system components included the RFID tags, 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. 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)

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coordinates of the Sentry, to a central P2S2 database via cell phone connection. MultiTrack uses web-based P2S2
software to track the HAZMAT. The P2S2 communication module is customizable with a variety of
communication, sensor and power options.  Prior to the start of the verification test, P2S2 staff set up the
MultiTrack according to their recommended configuration for optimal performance.

VERIFICATION RESULTS

Accuracy and precision. The table below summarizes the accuracy, precision, and data completeness of the
MultiTrack system.
Truck
Route
RT1-US
RT2-US
RT3-MX
RT4-MX
Accuracy (Identified Tags/Total
Tags) + 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. The MultiTrack system
made 1,481 of those identifications correctly, for an overall accuracy of 99.5%.

The two MX round trips included 34-minute periods that the truck was apparently out of the required cell phone
coverage area. During this time, the GPS tracking data were stored and transmitted upon regaining adequate
phone 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 was 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 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 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 electronic fence was identified as a "geo-fence or route builder" which provided a detailed
visual track on the mapping web page. 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.

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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 phone 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).
original signed by Lisa McCauley
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.

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