United States

Environmental Protection

Agency

Environmental Technology

Verification Report

Rechargeable Alkaline

Household Battery System

Rayovac Corporation, Renewal®

Office of Research and

Development

Washington, DC 20460

EPA/600/R-99/005

March 1999
EPA/600/R-99/005

Environmental Technology

Verification Report

Rechargeable Alkaline Household Battery

System

Rayovac Corporation, Renewal®

By

Terry Escarda, Project Manager

California Environmental Protection Agency

Department of Toxic Substances Control

Office of Pollution Prevention and Technology Development

Sacramento, California 95812-0806

Norma M. Lewis, Project Manager

Sustainable Technology Division

National Risk Management Research Laboratory

Cooperative Agreement No. CR 824433-01-0

U.S. ENVIRONMENTAL PROTECTION AGENCY

OFFICE OF RESEARCH AND DEVELOPMENT

NATIONAL RISK MANAGEMENT RESEARCH LABORATORY

CINCINNATI, OHIO 45268 
ii

Notice

The information in this document has been funded in part by the U.S. Environmental Protection

Agency (EPA) under a Cooperative Agreement (CR 824433-01-0) with the California

Environmental Protection Agency (Cal/EPA), Department of Toxic Substances Control (DTSC). 

This verification effort was supported by the Hazardous Waste Treatment and Pollution

Prevention Pilot Project under the EPA Environmental Technology Verification (ETV) Program. 

This verification effort has been subjected to EPA’s and Cal/EPA’s peer and administrative

review, and has been approved for publication as an EPA document.

This verification of the performance of the Rayovac Renewal® Rechargeable Alkaline Household

Battery System (Renewal® System) is the first time EPA based a verification of a hazardous

waste treatment or pollution prevention technology on a certification by DTSC, and is limited to

the use of Rayovac’s Renewal® System. The Renewal® System was certified by DTSC under the

California Hazardous Waste Environmental Technology Certification Program as a pollution

prevention technology on April 6, 1998. EPA and DTSC make no express or implied warranties

as to the performance of the Renewal® System. Nor do EPA and DTSC warrant that the

Renewal® System is free from any defects in workmanship or materials caused by negligence,

misuse, accident or other causes. Mention of corporation names, trade names, or commercial

products does not constitute endorsement or recommendation for use of specific products.
iii

Foreword

The Environmental Technology Verification (ETV) Program has been established by the U.S.

Environmental Protection Agency (EPA) to evaluate the performance characteristics of

innovative environmental technologies across all media and to report this objective information

to the permitters, buyers, and users of environmental technology. EPA’s Office of Research and

Development (ORD) has established a five year pilot program to evaluate alternative operating

parameters and determine the overall feasibility of a technology verification program. ETV

began in October 1995 and will be evaluated through October 2000, at which time EPA will

prepare a report to Congress containing the results of the pilot program and recommendations for

its future operation.

EPA’s ETV Program, through the National Risk Management Research Laboratory (NRMRL),

has partnered with the California Department of Toxic Substances Control (DTSC) under an

ETV Pilot Project to verify hazardous waste pollution prevention, recycling, or treatment

technologies. This Pilot Project focuses on, but is not limited to, hazardous waste management

technologies used in several EPA “Common Sense Initiative” industry sectors: printing,

electronics, petroleum refining, metal finishing, auto manufacturing, and iron and steel

manufacturing.

The following report describes the verification of the performance of the Rayovac Renewal®

Rechargeable Alkaline Household Battery System.
iv

Acknowledgment

DTSC acknowledges the support of all those who helped plan and conduct the verification

activities. In particular, we would like to thank Ms. Norma Lewis, EPA ETV Project Manager,

and Mr. Sam Hayes, EPA ETV Project Quality Assurance Manager, of EPA’s National Risk

Management Research Laboratory in Cincinnati, Ohio. We would also like to thank Dr. C.

Richard Walk, Director, Tracor Applied Sciences Battery Testing Facility, Rockville, Maryland,

for his assistance in developing and interpreting energy capacity tests. Toxicity Characteristic

Leaching Procedure sampling and analysis was performed by MVTL Laboratories of Oak Creek,

Wisconsin. Finally, we would like to acknowledge the assistance and participation of Mr. Ray

Balfour and Mr. Rod Donaldson of Rayovac Corporation.
 MARCH 1999

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

Office of Research and Development

Washington DC 20460

ENVIRONMENTAL TECHNOLOGY VERIFICATION STATEMENT

TECHNOLOGY TYPE: RECHARGEABLE ALKALINE HOUSEHOLD BATTERY

SYSTEM

APPLICATION: 1.5 VOLT BATTERIES IN STANDARD SIZES AAA, AA, C,

AND D

TECHNOLOGY NAME: RENEWAL®

COMPANY: RAYOVAC CORPORATION

ADDRESS: 601 RAYOVAC DRIVE

MADISON, WISCONSIN 53711-2497

P.0 BOX 44960

PHONE: (608) 275-4584

FAX: (608) 278-6666

The U.S. Environmental Protection Agency (EPA) has created a program to facilitate the

deployment of innovative environmental technologies through performance verification and

information dissemination. The goal of the Environmental Technology Verification (ETV)

Program is to enhance environmental protection by substantially accelerating the acceptance and

use of innovative, improved, and more cost-effective technologies. The ETV Program is

intended to assist and inform those individuals in need of credible data for the design,

distribution, permitting, and purchase of environmental technologies. This Verification

Statement provides a summary of the performance results for the Rayovac Corporation’s

Rechargeable Alkaline Household Battery System, trade name Renewal®.

v
vi

 MARCH 1999

PROGRAM OPERATION

The EPA’s ETV Program, in partnership with recognized testing organizations, objectively and

systematically documents the performance of commercial ready technologies. Together, with the

full participation of the technology developer, they develop plans, conduct tests, collect and

analyze data, and report findings. Verifications are conducted according to a rigorous workplan

and established protocols for quality assurance. Where existing data are used, the data must have

been collected by independent sources using similar quality assurance protocols. The EPA’s

ETV Program, through the National Risk Management Research Laboratory (NRMRL), has

partnered with the California Department of Toxic Substances Control (DTSC), under an ETV

Pilot Project, to verify the performance of pollution prevention, recycling, and waste treatment

technologies. 

TECHNOLOGY DESCRIPTION

Rayovac redesigned their alkaline household batteries so that they could be recharged. The

additional charge cycles extend battery life by increasing the energy capacity, which benefits the

environment by generating less waste. The design changes included increased void space, and

addition of lead and silver. The Rayovac Renewal® Rechargeable Alkaline Household Battery

System consists of rechargeable alkaline zinc-manganese dioxide 1.5 volt batteries, in sizes

AAA, AA, C, and D, and a recharging device for the batteries. Typical consumer applications of

household batteries include toys and games, portable audio equipment, cameras, sporting goods

equipment, test equipment, personal care products, hearing aids, portable data terminals, subnotebook computers and personal digital assistants, watches, flashlights, lanterns, and cellular

phones. Such applications typically require continuous currents of up to 400 milliamperes

(mA), which is within the range of the Renewal® batteries, sizes AA, C, and D. Size AAA can

supply up to 150 mA continuous current, which is sufficient for applications such as clocks. 

EVALUATION DESCRIPTION

The approach of this evaluation was to verify the independent data for energy capacity

performance previously collected as part of the DTSC certification, and to collect additional data

for toxicity and cost. The specific objectives were to:

 1) determine the initial and cumulative capacity of the Renewal® System’s batteries under

controlled laboratory conditions using, to the extent possible, industry-accepted standard

tests that model typical consumer applications, and to compare the Renewal® batteries’

performance to that of Rayovac’s non-rechargable alkaline batteries;

 2) determine what levels of federally regulated toxic metals might leach from the Renewal®

System’s batteries, using the federal Toxicity Characteristic Leaching Procedure (TCLP)

test method; and

3) estimate consumer costs, using conservative calculations and independently verified cost

and performance data. 
vii

 MARCH 1999

Availability of independent data limited performance verification to initial, five, and twenty-five

cycle energy capacity tests. Initial energy capacity indicates how much energy a battery contains

when first used, while cumulative energy capacity indicates the total energy the battery yielded

after a series of discharge/charge cycles. TCLP data are used to determine if a waste is regulated

as hazardous by EPA, and to estimate land disposal impacts of the waste.

In 1995, Tracor, Inc., a contractor with an independent battery testing facility, conducted several

series of American National Standards Institute (ANSI) energy capacity tests. Tracor conducted

a total of 12 tests on four sizes of Renewal® batteries. The tests measure how long a battery

provides energy under conditions that simulate the electrical load and cutoff voltage of typical

consumer devices such as toys, tape players, portable lighting, or transistor radios. (The cutoff

voltage is the lowest voltage on which a device will operate.) The batteries were drained,

charged to their initial voltage, and drained again to their cutoff voltage for a total of five cycles. 

Each test was conducted on four batteries of the same size so performance variability could be

analyzed. In 1996, four Size AAA batteries were further tested for 25 cycles. For ETV, in 1998,

TCLP tests were performed for all four sizes of the Renewal® batteries. For TCLP results, the

batteries were purchased, prepared, and analyzed by an independent analytical laboratory.

Details of the evaluation, including data summaries and discussion of results, may be found in

the report entitled, “U.S. EPA Environmental Technology Evaluation Report: Rayovac Renewal®

Rechargeable Alkaline Household Battery System” (EPA/600/R-99/005).” 

VERIFICATION OF PERFORMANCE

The observed performance characteristics of the Renewal® System include the following:

& Energy Capacity:

The initial energy capacity of the Renewal® batteries, as compared to non-rechargeable 

alkaline batteries of the same size, was as follows: Size AAA: 4.0 hours (51.9% of that of

a nonrechargeable alkaline), size AA: 4.0 hours (76.0%), size C: 14.4 hours (81.4 %), and

size D: 14.7 hours (89.6%). 

After five cycles, for sizes AAA and AA, the Renewal® batteries produced cumulative

hours of service that ranged between that produced by two and three non-rechargeable

alkaline batteries of the same size. For sizes C and D, the Renewal batteries produced

cumulative hours of service that ranged between that produced by two and four nonrechargeable alkaline batteries of the same size.

After 25 cycles, for size AAA, the Renewal® batteries produced cumulative hours of

service that ranged between seven and eight non-rechargeable alkaline batteries. 
viii

 MARCH 1999

& Toxicity Tests:

TCLP results for all metals were below their respective EPA regulatory limits. Only

barium and silver were found above the detection limits; barium was found at two orders

of magnitude below its regulatory limit, while silver was found at one order of magnitude

below its regulatory limit. The maximum results are listed below (in milligrams per

liter); results below detection limits are listed as <(detection limit):

METAL Arsenic Barium Cadmium Chromium Lead Mercury Selenium Silver

REGULATORY

LIMIT 5.0 100.0 1.0 5.0 5.0 0.2 1.0 5.0

MAXIMUM

DETECTED <0.036 0.32 <0.0068 <.065 <.029 <.0083 <.39 0.19

* Regulatory Limit values are EPA TCLP regulatory thresholds, 40CFR261.24, 1997.

& Cost Estimates: 

Consumer capital and operating costs were estimated and compared to non-rechargeable

alkaline batteries by purchasing batteries in packs of four at 1998 prices. Capital costs

include the cost of batteries and charger; the only operating cost is the cost of electricity

for charging. Renewal® batteries cost slightly more than twice that of Rayovac nonrechargeables, and the cost of chargers ranges from $10 to $20 before rebates. The

average cost to charge four batteries was conservatively estimated to be three fourths of a

cent. A savings of $2 to $12 per pack of four is estimated as compared to nonrechargeables. This savings is based on a useful life of at least 25 charges, and varies

depending on the size of batteries and type and number of chargers purchased.
ix

 MARCH 1999

Results of the verification show that the Renewal® System is capable of reducing waste volume

by extending battery life through recharging. The amount reduced depends on the battery size,

application type, and user practices such as frequency of charging. In addition, no TCLP results

were above EPA levels for regulating metals as hazardous waste, and were below detection limits

for most metals. Finally, the costs of the Renewal® System were compared to the costs of nonrechargeable alkaline batteries for Size AAA. For this case, based on 25 useful charging cycles,

total costs were estimated to be lower for the Renewal® System. Actual savings depends on

current prices, the type and number of batteries and chargers purchased, and user applications

and practices. 

Original Signed By Original Signed By

E. Timothy Oppelt James. T. Allen, Ph.D.

3/26/99 3/19/99

 

E. Timothy Oppelt Date James T. Allen, Ph.D. Date

Director, National Risk Management Chief, Office of Pollution Prevention 

 Research Laboratory And Technology Development

Office of Research and Development Department of Toxic Substances Control 

United States Environmental California Environmental Protection Agency 

 Protection Agency

 

Notice: Verifications are based on an evaluation of technology performance under specific,

predetermined criteria and the appropriate quality assurance procedures. EPA and Cal/EPA

make no expressed or implied warranties as to the performance of the technology. The user is

solely responsible for complying with any and all applicable federal, state, and local

requirements. 
x

 MARCH 1999

Availability of Verification Statement and Report

Copies of the public Verification Statement (EPA/600/R-99/005VS) and Verification Report (EPA/600/R-99/005)

are available from the following:

(Note: Appendices are not included in the Verification Report. Appendices are available from DTSC upon

request.)

 1. US EPA / NSCEP

P.O. Box 42419

Cincinnati, Ohio 45242-2419

Web site: http://www.epa.gov/etv/library.htm (electronic copy)

 http://www.epa.gov/ncepihom/ (hard copy)

 2. Department of Toxic Substances Control

Office of Pollution Prevention and

 Technology Development

P.O. Box 806

Sacramento, California 95812-0806

Web site: http://www.dtsc.ca.gov/sppt/opptd/etv/txppetvp.htm

or http://www.epa.gov/etv (click on partners)
xi

TABLE OF CONTENTS

Page

Notice . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii

Foreword . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iii

Acknowledgment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iv

Verification Statement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . v

Abbreviations and Acronyms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xiii

Executive Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

Section 1. Introduction ........................................................4

1.1. ETV Program Background ............................................4

1.2. Problem Description ... ..............................................4

1.3. Problem Solution . .................................................5

 1.4. Verification Objectives ...............................................5

Section 2. Technology Description ...............................................6

 2.1. Batteries ..........................................................6

 2.1.1. Household Batteries ............................................6

 2.1.2. Renewal® Batteries . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

 2.2. Renewal® Charging Devices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

Section 3. Performance Verification Tests . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

 3.1. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

 3.2. Performance Measures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

 3.2.1. ANSI Energy Capacity Tests . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

 3.2.2. Modified ANSI Energy Capacity Tests . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

 3.3. Independent Tests . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

 3.4. Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

 3.5. Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

3.6. Conclusions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

Section 4. Toxicity Characteristic Leaching Procedure (TCLP) Tests . . . . . . . . . . . . . . . . . . . 23

4.1. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

4.2. Sampling and Analyses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

 4.2.1. Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

 4.2.2. Sample Preparation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

 4.2.3. TCLP Analyses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

4.3. Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

 4.4. Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

4.5. Conclusions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

Section 5. Cost Estimates . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

Section 6. Applications Assessments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30
xii

Section 7. References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32

Availability of this Report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33

LIST OF TABLES

Table 2-1 Household Batteries . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

Table 3-1 ANSI C18.1M-1992 Battery Specification Alkaline Manganese Dioxide, Size AAA . . . . . 14

Table 3-2 ANSI C18.1M-1992 Battery Specification Alkaline Manganese Dioxide, Size AA . . . . . . 15

Table 3-3 ANSI C18.1M-1992 Battery Specification Alkaline Manganese Dioxide, Size C . . . . . . . . 15

Table 3-4 ANSI C18.1M-1992 Battery Specification Alkaline Manganese Dioxide, Size D . . . . . . . . 16

Table 3-5 Renewal vs. Primary Alkaline: Performance Hours of Service . . . . . . . . . . . . . . . . . . . . . 20

Table 4-1 Summary Sheet: TCLP Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

Table 5-1 Typical Rayovac Retail Prices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

Table 5-2 Costs for Various Amounts of Rayovac Batteries . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

LIST OF FIGURES

Figure 2-1 Illustration of Renewal® Batteries . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

Figure 2-2 Illustration of Power StationTM Chargers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

Figure 3-1 Size AAA Renewal® Capacity Fade Trends . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

APPENDICES (Available from DTSC upon request)

 Appendix A -- TRACOR Statement of Qualifications

 Appendix B -- Tracor Performance Laboratory Report

 Appendix C -- TCLP Laboratory Report
xiii

LIST OF ACRONYMS

AB Assembly Bill

Ah Ampere-hours

ANSI American National Standards Institute

Cal/EPA California Environmental Protection Agency

CIWMB California Integrated Waste Management Board

DTSC California Department of Toxic Substances Control

EP Extraction Procedure

EPA United States Environmental Protection Agency

ETV Environmental Technology Verification Program

HML Hazardous Materials Laboratory (State of California)

IRIS Integrated Risk Information System

kg kilograms

l liter

mA milliamperes

mg milligrams

NiCd nickel-cadmium

NiMh nickel-metal hydride

NEMA National Electrical Manufacturers Association

NRMRL National Risk Management Research Laboratory

OEHHA Office of Environmental Health Hazards Assessment

OPPTD Office of Pollution Prevention and Technology Development

ORD Office of Research and Development (EPA)

OEM Original Equipment Manufacturers

ppm parts per million

QA/QC Quality Assurance/Quality Control

RCRA Resource Conservation and Recovery Act

Renewal Registered Trade Name for Rayovac’s Rechargeable Alkaline Battery

SB Senate Bill

TCLP Toxicity Characteristic Leaching Procedure

V Volts
1

Executive Summary

Background

The U.S. Environmental Protection Agency (EPA) created the Environmental Technology

Verification (ETV) Program to facilitate the deployment of innovative technologies through

performance verification and information dissemination. EPA, through its National Risk

Management Research Laboratory (NRMRL) in Cincinnati, Ohio, has partnered with the

California Department of Toxic Substances Control (DTSC), to verify pollution prevention,

recycling, and waste treatment technologies under one of twelve ETV Pilot Projects. This Pilot

Project is based on California’s existing Hazardous Waste Environmental Technology

Certification Program (Certification Program). DTSC, under authority of Section 25200.1.5.,

California Health and Safety Code, established the Hazardous Waste Environmental Technology

Certification Program in 1994. This Pilot Project focuses on, but is not limited to, several EPA

“Common Sense Initiative” industry sectors: printing, electronics, petroleum refining, metal

finishing, auto manufacturing, and iron and steel manufacturing. The Renewal® System was

certified by DTSC as a pollution prevention technology on April 6, 1998.

Technology Description

The Rayovac Renewal® Rechargeable Alkaline Household Battery System consists of

rechargeable alkaline zinc-manganese dioxide 1.5 volt batteries, in sizes AAA, AA, C, and D,

and a recharging device/method for the batteries. Typical consumer applications of household

batteries include toys and games, portable audio equipment, cameras, sporting goods equipment,

test equipment, personal care products, hearing aids, portable data terminals, sub-notebook

computers and personal digital assistants, flashlights, lanterns, and cellular phones.

Verification Approach

Rayovac redesigned alkaline household batteries so that they could be recharged. The additional

charge cycles increase the battery energy capacity, extending battery life, which benefits the

environment by reducing waste. The objectives of the verification project were to determine the

performance using the existing verified independent data for energy capacity collected as part of

the California Certification Program project, and to collect additional data on toxicity and cost. 

Availability of independent data limited performance verification to initial, five, and twenty-five

cycle cumulative energy capacity tests. Initial energy capacity indicates how much energy a

battery contains when first used, while cumulative energy capacity indicates the total energy the

battery yielded after a series of charge/discharge cycles.

In 1995, as part of the California Certification Program, Tracor Inc., an independent battery

testing facility, conducted several series of American National Standards Institute (ANSI) energy 

capacity tests on Renewal® batteries. The tests measure how long a battery provides energy

under conditions that simulate the electrical load and cutoff voltage of typical consumer devices

such as toys, tape players, portable lighting, or transistor radios. (The cutoff voltage is the lowest

voltage on which a device will operate.) The batteries were drained to the test-specified cutoff
2

voltage, charged to their initial voltage, and drained again to their cutoff voltage for a total of five

cycles. Each test was conducted on four batteries so performance variability could be analyzed. 

In 1996, Size AAA batteries were tested for 25 cycles. For ETV, in 1998, federal Toxicity

Characteristic Leaching Procedure (TCLP) tests were performed for all four sizes of the

Renewal® batteries. The batteries were purchased, prepared, and analyzed by an independent

analytical laboratory. Cost data were gathered in 1998 by DTSC staff surveying retail outlets and

electricity utilities.

Verification Results

The observed performance characteristics of the Renewal® System include the following:

Objective #1 - Energy Capacity Determination

The initial energy capacity of the Renewal® batteries, as compared to non-rechargeable alkaline

batteries of the same size, was as follows: Size AAA: 4.0 hours (51.9% of that of a

nonrechargeable alkaline), size AA: 4.0 hours (76.0%), size C: 14.4 hours (81.4 %), and size D:

14.7 hours (89.6%). After five cycles, for sizes AAA and AA, the Renewal® batteries produced

cumulative hours of service that ranged between that produced by two and three nonrechargeable alkaline batteries of the same size. For sizes C and D, the Renewal batteries

produced cumulative hours of service that ranged between that produced by two and four nonrechargeable alkaline batteries of the same size. After 25 cycles, for size AAA, the Renewal®

batteries produced cumulative hours of service that ranged between seven and eight nonrechargeable alkaline batteries of the same size. (Rayovac reported similar results for Sizes AA,

C, and D, but those tests were not independently verified.) 

 

Objective #2 - Toxicity Determination:

The federal Toxicity Characterization Leaching Procedure (TCLP) test was performed to

determine what levels of toxic metals might leach from the batteries. TCLP results for all metals

were below their respective EPA regulatory limits. Only barium and silver were found above the

detection limits; barium was found at two orders of magnitude below its regulatory limit, while

silver was found at one order of magnitude below its regulatory limit. The maximum results are

listed below (in milligrams per liter); results below detection limits are listed as <(detection

limit):

METAL Arsenic Barium Cadmium Chromium Lead Mercury Selenium Silver

REGULATORY

LIMIT 5.0 100.0 1.0 5.0 5.0 0.2 1.0 5.0

MAXIMUM

DETECTED <0.036 0.32 <0.0068 <.065 <.029 <.0083 <.39 0.19

* Limits are US EPA TCLP regulatory thresholds, 40CFR261.24, 1997
3

Objective #3 - Cost Estimates: 

Consumer capital and operating costs were estimated and compared to non-rechargeable alkaline

batteries by purchasing batteries in packs of four at 1998 prices. Capital costs include the cost of

batteries and charger; the only operating cost is the cost of electricity for charging. Rayovac

estimates the life expectancy of the chargers to be five years. Renewal® batteries cost slightly

more than twice that of Rayovac non-rechargeables, and the cost of chargers ranges from $10 to

$20 before rebates. The average cost to charge four batteries was conservatively estimated to be

three fourths of a cent. A savings of $2 to $12 is estimated as compared to non-rechargeables. 

This savings is based on a useful life of at least 25 charges, and varies depending on the type of

batteries and charger purchased.
4

Section 1

 Introduction

This section provides background on the U.S. Environmental Protection Agency’s (EPA)

Environmental Technology Verification (ETV) Program, especially its partnership with

California, introduces the Rayovac Renewal® System verification project, including the project’s

unique focus on existing independent objective data, and describes the project’s verification

objectives. 

1.1. ETV Program Background

EPA created the ETV Program in 1995 to facilitate the deployment of innovative commercialready technologies through performance verification and information dissemination. EPA,

through its National Risk Management Research Laboratory (NRMRL), has partnered with the

California Department of Toxic Substances Control (DTSC) under an ETV Pilot Project to verify

hazardous waste pollution prevention, recycling, and waste treatment technologies. The Pilot

Project is based on California’s existing Hazardous Waste Environmental Technology

Certification Program (Certification Program). The DTSC Office of Pollution Prevention and

Technology Development (OPPTD), under authority of Section 25200.1.5., California Health

and Safety Code, established the Certification Program in 1994. The Pilot Project focuses on,

but is not limited to, hazardous waste management technologies used in several EPA “Common

Sense Initiative” industry sectors: printing, electronics, petroleum refining, metal finishing, auto

manufacturing, and iron and steel manufacturing. 

The performance verification contained in this report is based on independent data collected and

documented as part of the California certification of Rayovac Corporation's Renewal® System. 

Moreover, this verification report presents additional hazardous metals leach test data by an

independent source using EPA’s Toxicity Characteristic Leaching Procedure. The Renewal®

System was certified as a pollution prevention technology on April 6, 1998. DTSC’s

certification report describes performance, recommended applications, regulatory implications,

specific conditions, and limitations, as well as providing the certification statement (2). From

these, and vendor-supplied data, DTSC concluded that the Renewal® System can reduce the

generation of hazardous waste.

1.2. Problem Description

The waste management of household batteries, also referred to as consumer or dry cell batteries,

is regulated by states and the federal government under special reclamation strategies. The term

“household battery” is used to define the general type of battery, not specific use; many

household batteries are used in industrial, commercial, or institutional settings.

The disposal of household batteries is a concern because of their wide-spread use, and the levels

of toxic metals such as mercury, cadmium, lead, nickel, and silver. In a 1992 report to the

California Integrated Waste Management Board, Ernst and Young analyzed national sales data
5

that indicate that about 5.5 billion household batteries will be sold in the year 2000; the largest

portion of which (about four billion) are projected to be alkaline (3). 

1.3. Problem Solution

Rayovac redesigned their alkaline household batteries so that they could be recharged. The

additional charge cycles extend battery life, and reduce waste. The redesign resulted in a change

of materials and a loss of initial energy capacity.

1.4. Verification Objectives

This project focused on verifying the independent performance data previously collected as part

of the DTSC certification that meet desired data quality objectives, including national versus

state-only applicability and quality assurance/quality control standards, and to collect additional

data for toxicity and cost. Existing performance data meeting these criteria are: initial energy

capacity, five-cycle and 25-cycle cumulative energy capacity, and 25-cycle energy capacity (for

size AAA only). Moreover, toxicity and cost data were collected during the verification project. 

The toxicity data are results of the Toxicity Characteristic Leaching Procedure (TCLP) test, the

EPA test for hazardous waste toxicity characteristic and disposal acceptance. 

Specifically, the objectives of this verification were to:

 1) determine the initial and cumulative capacity of the Renewal® System’s batteries under

controlled laboratory conditions, using to the extent possible industry-accepted standard

tests that model typical consumer applications, and to compare the Renewal® batteries’

performance to that of Rayovac’s non-rechargable alkaline batteries;

 2) determine levels of federally regulated toxic metals that might leach from the Renewal ®

System’s batteries, using the federal Toxicity Characteristic Leaching Procedure (TCLP)

test method; and

3) estimate consumer costs, using conservative calculations and independently verified cost

and performance data.
6

Section 2

Technology Description

2.1. Batteries

Batteries consist of two electrodes with different electrical potentials immersed in an electrically

conducting medium (electrolyte). The positive electrode is termed the cathode; the negative

electrode, anode. A battery transforms chemical energy into electrical energy. As ions flow

through the electrolyte to the electrodes, electric current is produced in an external circuit. 

Battery types differ in materials used for the electrodes or electrolyte; this leads to varying

characteristics such as storage life, power, operating time, and cost. 

2.1.1. Household Batteries

Generally, household batteries are of nominal 1.5 volts (V), and come in standard cylindrical

sizes (AAA, AA, C, or D), as well as button shapes. Button cells are generally used for hearing

aids or watches. Household batteries use a “dry” electrolyte which is actually a moist or solid

paste or gel.

Household batteries are of two major types: “Primary” batteries are those constructed so that only

one continuous or intermittent discharge can be obtained, whereas “secondary” batteries can be

recharged for multiple uses by applying an electrical current to the battery to reestablish the

electrical potential. Lead-acid automobile batteries are explicitly defined and regulated

separately from household batteries. 

Primary household batteries include: carbon-zinc, alkaline, silver oxide, and lithium. Secondary

household batteries include: nickel-cadmium (NiCd), lithium-ion, and rechargeable alkaline

manganese (RAM). Rayovac’s Renewal® batteries are RAM batteries.

The following is a brief description of the major types of household batteries (3):

PRIMARY (non-rechargeable):

& carbon-zinc - contain a zinc anode and carbon cathode with ammonium chloride (general

purpose) or zinc chloride (heavy-duty) electrolyte.

& alkaline - contain a zinc anode and manganese dioxide cathode with a strongly alkali

electrolyte, typically potassium hydroxide. Alkaline batteries historically have been nonrechargeable (primary) batteries with five to eight times the service life of carbon-zinc

batteries.

& silver oxide - are often used in place of mercuric oxide for longer life button cells.

& zinc-air - Atmospheric oxygen acts as the cathode and the space normally containing the
7

cathode is filled with the zinc anode, thus doubling service life. They must be exposed to

air to function; therefore, they cannot be used in applications such as watches that have a

relatively tight seal.

& lithium - are also a relatively recent innovation. Primary lithium batteries are used in

applications such as cameras, calculators, watches, and pacemakers. They also have the

longest shelf life, losing only one percent of power per year.

SECONDARY (rechargeable):

& nickel-cadmium (NiCd) - NiCds are the most common type of secondary household

battery. NiCds typically only last about one-third as long as alkaline, but can be

recharged several hundred times. NiCds can provide higher currents than most household

batteries due to their cell structure, allowing their use in applications such as portable

power tools.

& Nickel-metal hydride (NiMH) - are similar to NiCds, and were developed in response to

concerns about NiCds’ toxicity.

& lithium-ion - a secondary version of lithium batteries, they are typically used in laptop

computers.

& rechargeable alkaline manganese (RAM) - trade name Renewal®. Combines the long life

of alkaline with the rechargeability of NiCds. Applications of these relatively new

batteries include high temperature uses and intermittent use requiring minimal discharge. 

Table 2-1 lists the major constituents found in the most common household batteries’ electrodes

and electrolytes, and the typical consumer application for those batteries.
8

Table 2-1. Household Batteries (Source: adapted from “Household Battery Waste Management Study: Final Report,” Ernst &

Young, 1992.)

Battery Type Battery Sizes Cathode Anode Electrolyte Typical Applications

Primary Batteries

Alkaline D, C, AA, AAA,

9V

Manganese Dioxide Zinc Potassium

Hydroxide

Toys, games, clocks, electronic flashes, tape recorders,

calculators, flashlights, radios, smoke alarms, cameras

Carbon-Zinca/ D, C, AA, 9V Carbon Zinc Ammonium

Chloride or Zinc

Chloride

Toys, games, flashlights, radios, tape recorders

Silver Oxide Button Silver Oxide Zinc Potassium

Hydroxide 

Watches, calculators, hearing aides, cameras

Zinc Air Button Atmospheric

Oxygen

Zinc Potassium

Hydroxide

Hearing aids, pagers

Lithium Buttonb/ Manganese Oxide Lithium Organic Solvent Cameras, calculators, pacemakers, watches

Secondary Batteries

NickelCadmiumD, C, AA, AAA,

9V

Nickel Oxide Cadmium Potassium

Hydroxide

Power hand tools, portable vacuums, computers, fire and

burglar alarms, electric razors, cordless and cellular

telephones, toys, games, video cameras, electric toothbrushes

Nickel-Metal

Hydride

Same as NickelCadmiumNickel

Oxyhydoxide

alloys or rare

earth metalsc/

Potassium

Hydroxide

Same as Nickel-Cadmium

Rechargeable 

Alkaline

Manganese

D, C, AA, AAA Manganese Dioxide Zinc, Lead Potassium

Hydroxide

Same as alkaline

a/ Includes “General Purpose” and “Heavy Duty” batteries. b/

 Lithium batteries are also available in C, AA, and 9V sizes; however, these sizes currently represent a negligible part of the market.

c/ NiMH anodes are of two general types: AB2

 Type: alloys containing vanadium, zirconium, titanium, chromium, nickel, cobalt, manganese and/or others. 

AB5

 Type: rare earth metals with nickel.
9

2.1.2. Renewal® Batteries

The Renewal® System consists of rechargeable alkaline zinc-manganese dioxide batteries, a

recharging device for the batteries, and pertinent technical and consumer literature. Figure 2-1 is 

an illustration of the Renewal® batteries. The design of the primary alkaline battery was changed

to allow recharging. More internal void space was introduced to allow for hydrogen gas created

when the battery is charged. In addition, silver oxide replaced part of the manganese dioxide

cathode, to act as a catalyst in recombining the hydrogen gas. Also, lead was added to the zinc

anode. These changes were necessary to prevent excessive water loss and internal pressure,

which could lead to leaking at dry seals or rupturing. However, the same changes reduced the

amount of zinc and manganese dioxide available and increased the internal void space, thus

reducing the initial energy capacity of the cell. 

The batteries have zinc anodes, manganese dioxide cathodes, and a “dry”, i.e. solid or moist

paste, alkaline (approximately 40% potassium hydroxide) electrolyte. Consumer applications

typically require continuous currents of up to 400 milliamperes. Typical consumer applications of

household batteries include toys and games, portable audio equipment, cameras, sporting goods

equipment, test equipment, personal care products, hearing aids, portable data terminals, subnotebook computers and personal digital assistants, watches, flashlights, lanterns, cellular

phones, etc. 

Rechargeable batteries are susceptible to “capacity fade”. Capacity fade refers to the loss of

energy capacity each time the battery is charged. Each time the battery is discharged and

subsequently recharged, the cell does not regain all of its previous capacity. Eventually the

battery’s capacity fades to the point that there is not enough capacity remaining for the cell to be

useful, and it must be discarded. The amount of capacity needed for the cell to be useful depends

on the application of the battery and the user’s preferences. For Renewal® batteries, capacity

fade is sensitive to depth of discharge, which is related to discharge rate and cut-off voltage. 

“Depth of discharge” refers to the amount of energy withdrawn from the cell by converting the

manganese dioxide to manganese trioxide. Limiting the depth of discharge will reduce the loss

in available capacity, i.e., capacity fade, for each successive discharge cycle.

Depth of discharge can be controlled by setting a cut-off voltage. For a specific cut-off voltage,

more fade occurs at lower discharge rates because the cut-off voltage is reached later due to less

pronounced internal resistance losses, and thus more capacity is removed. Therefore, setting a

cut-off voltage higher for low discharge rates will reduce capacity fade. For a specific discharge

rate, more capacity fade will occur when the batteries are discharged to a lower cut-off voltage

because more capacity is removed from the cell. At higher discharge rates, the internal resistance

losses will cause the voltage to drop before all of the available capacity is withdrawn. Internal

resistance losses are higher at higher discharge rates because the cells are of the “bobbin,” or

cylinder type, as opposed to spiral-wound. This bobbin design allows high capacity, but causes

higher internal resistance. In either case, not all the capacity can be regained because the

chemical reactions are not completely reversible, therefore, after a certain number of cycles the

batteries will no longer gain useful capacity. 
10

FIGURE 2-1. Rayovac Renewal® Batteries
11

2.2. Renewal Charging Devices

The Rayovac Renewal® charging device is known as a Power StationTM. The Power StationTM

recharger comes in two sizes: PS1 for a combination of AA and AAA batteries, and PS3 for a

combination of one to eight AA, AAA, C, and D batteries. The PS3 will accept RAM, NiCd,

and NiMH batteries. Figure 2-2 is an illustration of the PS3 charging device. 

The PS1 and Renewal® batteries are designed so that only Renewal® batteries can be charged by

the PS1 (4) without compromising the ability of the Renewal® batteries to be used in electronic

devices. This is accomplished by two methods, one for battery sizes C and D, and another for

sizes AAA and AA (5). For example, Renewal® Sizes AAA and AA have an exposed metal

layer on the top of the cell case whereas conventional alkaline cells have an insulating layer

covering this surface. When any AA or AAA size battery other than a Renewal® is placed in the

charging unit, the charge contact is blocked by the plastic label overwrap of the cell and no

charge current can be applied.

According to Rayovac, Renewal® batteries should be charged only by Rayovac's charging device

and method because, "Methods of charging which have been used in NiCd systems such as

continuous trickle-charging or constant-current fast charge are not suitable for use with

rechargeable alkaline batteries. The alkaline cells are not tolerant of high continuous charge

currents, and may be damaged if high current is forced into them after they have reached a

partially recharged state."(6) Products which have Rayovac's charging technology built in can

operate on other types of batteries, but will only recharge Renewal® batteries.

The charging method consists of a "... pulse charge method. Fixed amplitude, variable duty cycle

pulses are applied to the battery during charge. The pulses are limited in amplitude by currentlimiting resistors. The duty cycle is modulated by a control chip (Application Specific Integrated

Circuit, or ASIC) specifically designed for use in the Renewal® Power Stations. The average

value of the charging current applied to the batteries is gradually reduced as the open-circuit

voltage of the battery increases during the charge... A Light Emitting Diode (LED) is activated

when the battery is properly placed into the charger; it is deactivated when three consecutive

charge pulses are disabled (the battery has stayed above the 1.65 [volt] reference value for this

period of time).”(6)
12

FIGURE 2-2. Rayovac Charging Unit (PS3)
13

Section 3

 Performance Verification Tests

3.1. Introduction

In the following sections, performance measures, test methods, data, observations, and

conclusions regarding performance are presented. The verification performance testing was

conducted by the Tracor Battery Technology Center, an independent testing facility.

3.2. Performance Measures

There are many ways of measuring a battery's performance, including initial capacity (Amperehours of service), usable cycles, nominal voltage range, energy density, output current under

continuous or pulse loads, self-discharge rate (i.e., charge retention or shelf life), charge time,

weight, sensitivity to temperature, susceptibility to leakage, cost, and ease of disposal. No one

battery performs best in all categories. Similarly, for battery chargers, there are a number of

ways of measuring a battery charger's performance, including time of recharge, ability to sense

when a battery is fully charged, ability to prevent overheating, and number and types of batteries

which can simultaneously be charged. 

The main measure of the pollution prevention performance of the Renewal® batteries is the

number of primary alkaline batteries that the Renewal® batteries can replace. For example, if a

primary alkaline battery provides 10 hours of service, i.e., capacity, and a Renewal® battery of the

same size provides 100 hours of useful cumulative capacity, then the Renewal® replaces 10

primary batteries. Therefore, the cumulative capacity of the Renewal® battery must be known in

order to compare its performance to that of the primary alkaline battery. 

Capacity is defined as the electrical output, expressed in ampere-hours (Ah), obtained from

discharging a cell at a specific current and temperature, to a specified end-of-discharge voltage

(7). Cumulative capacity is the hours of service after repeated discharge and charge cycles as

measured by continuous tests, under specified loads to specified voltage-cutoffs, which

correspond to certain typical consumer applications. 

3.2.1. ANSI Energy Capacity Tests

Capacity is expressed in terms of service life using a given load (electrical resistance), schedule

(for intermittent tests), and discharge to a specified endpoint voltage. Changes in test procedures

are determined by market studies and electronic characterization of popular classes of appliances. 

Prior to 1992, ANSI capacity test methods specified that the tests be continuous in nature -- the

batteries were continuously drained from the nominal voltage to the specified cutoff voltage. 

However, the battery manufacturers recognized that in actual practice devices are typically used

for a certain time period, then rested. Thus, in 1992, intermittent test schedules were developed

(8). In contrast to continuous tests, intermittent schedules require that the test be suspended after
14

a specified length of time prior to reaching the cutoff voltage, the batteries allowed to rest and

recover, and the test continued until the cutoff voltage or next rest period is reached. For large

size batteries operated under low drain conditions, intermittent tests substantially increase the

amount of time required to complete the test.

The size and type of batteries and conditions of use determine the test specification to be applied. 

The test specification that best represents any particular use is that which most nearly duplicates

the load, schedule, and end-point voltage when in actual use. Tables 3-1, 3-2, 3-3, and 3-4 are

the ANSI C18.1M-1992 battery testing specification sheets, including capacity tests, for 1.5V

alkaline zinc-manganese batteries, sizes AAA, AA, C, and D, respectively. From Table 3-1, for

example, the four variations of testing of size AAA alkaline zinc manganese batteries are based

on typical uses, e.g., photography, portable lighting, personal tape recorders/cassette players, and

transistor radios. To approximate the requirements of a cassette player, the test conditions are at

a resistance of 10 ohms, test schedule of one hour per day, and an end-point of 0.9V. 

Table 3-1. ANSI C18. 1M-1992 Specifications, Alkaline Manganese Dioxide, Size AAA

LOAD (Ohms)

TEST

SCHEDULE

END

POINT(Volts)

TYPICAL

PERFORMANCE TYPICAL USE

INITIAL 12 MONTHS

3.6

15 SEC/MIN, 

 24 HRS 0.9

 450 

PULSES 405 PULSES

PULSE TEST

(PHOTO)

5.1

 4 MIN / HR, 

8 HRS / DAY 0.9 125 MIN 112 MIN

PORTABLE

LIGHTING

10 1 HR/ DAY 0.9 5.5 HRS 5 HRS

PERSONAL TAPE

RECORDER &

CASSETTE

PLAYER

75 4 HRS/DAY 0.9 48 HRS 43 HRS

TRANSISTOR

RADIO
15

Table 3-2. ANSI C18. 1M-1992 Specifications, Alkaline Manganese Dioxide, Size

AA

LOAD

(Ohms)

TEST

SCHEDULE

END POINT

(Volts)

TYPICAL

PERFORMANCE

TYPICAL USE

INITIAL 12 MONTHS

1.8 15 SEC/MIN, 

 24 HRS

0.9 360

PULSES

324

PULSES

PULSE TEST

(PHOTO)

3.9 1 HR/DAY 0.8 5 HRS 4.5

HRS

MOTOR & TOYS

10 1 HR/ DAY 0.9

13.5

HRS

12

HRS

PERSONAL TAPE

RECORDER &

CASSETTE PLAYER

75 4 HRS/DAY 0.9 115

HRS

104

HRS

TRANSISTOR RADIO

Table 3-3. ANSI C18. 1M-1992 Specifications, Alkaline Manganese Dioxide, Size C

LOAD

(Ohms)

TEST

SCHEDULE

END POINT

(Volts)

TYPICAL

PERFORMANCE TYPICAL USE

 

 INITIAL

12

MONTHS

3.9

4 MIN/HR, 

8HRS/DAY 0.9 830 MIN 737 MIN

PORTABLE

LIGHTING

3.9 1 HR / DAY 0.8 14.5 HRS 13 HRS TOYS

6.8 1 HR/ DAY 0.9 24 HRS 22 HRS TAPE RECORDER

39 4 HRS/DAY 0.9 160 HRS 144 HRS TRANSISTOR RADIO
16

Table 3-4. ANSI C18. 1M-1992 Specifications, Alkaline Manganese Dioxide, Size D

LOAD (Ohms)

TEST

SCHEDULE

END POINT

(Volts)

TYPICAL

PERFORMANCE TYPICAL USE

 

INITIAL

12

MONTHS

2.2

4 MIN/HR,

 8 HRS/DAY 0.9 800 MIN 720 MIN

PORTABLE

LIGHTING

2.2 1 HR/ DAY 0.8 15.5 MIN 13.9 MIN TOYS

3.9 1 HR/ DAY 0.9 26 HRS 23.5 HRS

TAPE

RECORDER

39 4 HRS/DAY 0.9 375 HRS 338 HRS

TRANSISTOR

RADIO

3.2.2. Modified ANSI Energy Capacity Tests

ANSI standard C18.1M-1992, Dry Cells and Batteries - Specifications, was sponsored by the

National Electrical Manufacturers Association (NEMA), and includes test procedures for

measuring the capacity of primary cells. 

In order to quantitatively and conservatively measure capacity, Rayovac and DTSC agreed to use

modified ANSI capacity tests and cumulative performance for 25 charging cycles. Twenty-five

cycles were chosen based on two factors. First, Rayovac had already performed tests to 25

cycles, so data which were comparable were desired. Second, limiting the number of charging

cycles to 25 was considered a reasonably conservative comparison to a primary alkaline battery. 

This is because the capacity of the Renewal® battery, as that of other rechargeables, decreases

each time it is charged. At some number of charging cycles the performance has decreased to the

point where the battery no longer has a useful capacity. Some Rayovac customers reported as

many as several hundred charge cycles with useful capacity (9). However, for other applications

useful capacity may not be achievable after fewer cycles.

The tests were modified to make them continuous discharge tests instead of interrupted discharge

tests; this was done so that the results could be obtained as quickly as possible, but also had the

effect of making the tests a more conservative measure of performance. The continuous tests

give more conservative results because the batteries do not have an opportunity to recover.
17

Recovery occurs after discharge when zinc ions from the anode diffuse towards the cathode and

combine with ammonia produced by the cathode reaction to produce complex ions. This

removes the ammonia that had decreased the available current by forming an insulating layer

around the cathode, thus allowing the batteries to recover (10). 

The ANSI tests were designed for measuring the capacity of single use primary batteries,

therefore, the tests were modified such that the batteries were charged for 16 hours, rested one

hour, then tested again per the ANSI procedures for non-rechargeable batteries.

In summary, modified energy tests were used for the following reasons:

1. No ANSI standard capacity tests for rechargeable alkaline batteries exist;

2. The standard tests upon which the modified tests are based were developed by consensus

of a variety of industry experts and stakeholders, thus the methods are widely accepted;

3. Tests are designed to replicate actual conditions of use for a variety of consumer

applications;

4. The methods are quantitative and the results reproducible; and

5. The modified tests for capacity are conservative due to continuous discharge, infrequent

charging, and high depth-of-discharge conditions.

3.3. Independent Tests

This section describes the performance tests and resulting data generated by an independent

testing facility. When Rayovac applied to the Cal/EPA Certification Program, DTSC did not

have the internal capability to test the performance of the batteries. Therefore, DTSC requested

that an independent firm, knowledgeable in battery performance testing, be retained to verify the

batteries' performance. Tracor, Inc., a defense contractor located in Rockville, Maryland, with an

in-house battery testing center, was retained to do the testing. For a description of Tracor's

battery testing qualifications, refer to Appendix A.

In September 1995, Tracor completed its initial performance comparison testing of primary,

nickel-cadmium, and Renewal® batteries. Rayovac submitted the data to DTSC in October

1995. DTSC also obtained the results directly from Tracor to verify their accuracy and

completeness. Comparing the results of the Tracor and Rayovac tests was complicated by the

fact that the tests which Tracor performed were not identical to the ones which Rayovac

themselves conducted. In some respects the Rayovac tests were more comprehensive, and in

other respects more limited.
18

The Tracor tests were more comprehensive in that Tracor used four batteries per test to analyze

performance variability, Tracor conducted tests for all of the ANSI recommended load and endpoint voltage specifications except for photoflashes, and Tracor used the Rayovac Power

StationTM Charger. Rayovac only tested one battery per size, using only the high drain test

conditions, and had a charging mechanism built directly into its test board. However, Tracor

only tested the first five cycles, whereas Rayovac performed 25 cycle testing.

In five of the 12 five-cycle tests conducted by Tracor, one of the four batteries being tested

exhibited performance which was less than 50 percent of the mean performance of the remaining

three cells, and was disqualified. This equates to five of 48 batteries or about 10 percent. Tracor

stated this is not unusual during battery testing (11). DTSC requested further testing for full 25

cycles because of concerns over the limited amount of data, discrepancies, and the specific nature

of the performance claims. Therefore, Tracor performed full 25-cycle testing on four size AAA

Renewal® batteries, considered the conservative size battery for capacity tests due to higher ratios

of void space and inert ingredients than the other sizes. Tracor completed those tests in October

1996. 

3.4. Results

Table 3-5, presents the results, as averages, of the testing performed by Tracor to verify the inhouse testing conducted by Rayovac. Refer to Appendix B for the Tracor Data Sheets, which

include statistical variation information.

Table 3-5 presents Tracor’s results as hours of service and as a percentage of the capacity of nonrechargeable alkaline batteries. The capacity of the Renewal® batteries is presented as initial

capacity (hours of service at the first cycle), hours of service at the fifth cycle, cumulative hours

of service at the fifth cycle, hours of service at the 25th cycle, and cumulative hours of service

after 25 cycles.

An explanation of the testing conditions listed in Table 3-5 is in order: “Load’ refers to the

electrical resistance, measured in ohms, applied to the testing circuit. The smaller the load, the

greater the current that can be drawn from the battery, and thus the faster the battery energy

capacity is depleted. Small loads correspond to applications such as portable lighting, medium

loads to toys or motors, and high loads to low-current devices such as transistor radios. 

“Endpoint voltage” simrefers to the cutoff voltage, measured in volts, below which the device is

designed not to operate. Typically, electronic devices are designed for cutoff voltages of 0.8 or

0.9 volts. Thus, for a given load, a cutoff voltage of 0.8 volts will lead to a greater depth-ofdischarge than an cutoff voltage of 0.9 volts.

The initial capacity ranged from approximately 47 percent to 70 percent of that of nonrechargeable alkaline battery of the same size, depending on the load and cutoff voltage. As the

battery size increased, so did the Renewal® batteries’ initial capacity relative to that of nonrechargeable alkaline batteries of the same size. For size AA, the Renewal®’s initial capacity
19

ranged from approximately 73 percent to 76 percent. For size C, the initial capacity ranged from

about 72 percent to 81 percent. For size D, the initial capacity ranged from about 69 percent to

90 percent. 

The five cycle tests provide useful information about the capacity fade over the first five cycles. 

From Table 3-5 and Figure 3-1, one can see that the energy capacity present after the fifth cycle

ranged from about 35 to 40 percent of the capacity of a size AAA non-rechargeable alkaline

battery. For size AA, the range was about 37 to 42 percent, for size C, it was about 45 to 57

percent and for size D, it was about 45 to 59 percent. However, in one low-drain (39 ohm) test

for size D, at the 5th cycle, the Renewal® batteries only had 16 percent of the capacity of a nonrechargeable size D alkaline battery. This is so far outside the other ranges that the possibility of

an outlier should be considered. In summary, after five cycles, the Renewal® batteries still

provide energy capacity from about 35 to 60 percent of that of non-rechargeable alkaline batteries

of the same size. The available relative energy capacity increases with the size of the battery. 

Users can determine if that energy capacity is sufficient on an application-specific basis.

The five-cycle cumulative capacity data in Table 3-5 follows a similar pattern as the initial

capacity data. The cumulative capacity of size AAA Renewal® batteries ranged from about 200 to

260 percent of the energy capacity of non-rechargeable size AAA alkaline batteries, for size AA

the range was 250 to 275 percent of size AA non-rechargeable alkaline batteries, for size C the

range was about 260 to 325 percent, and for size D the range was about 170 to 325 percent. In

other words, after five cycles the Renewal® batteries provided the energy of about two nonrechargeable alkaline batteries for sizes AAA and AA, and about three non-rechargeable alkaline

batteries for sizes C and D.

Data from the size AAA 25-cycle capacity tests conducted by Tracor are summarized in the last

four columns of Table 3-5. Also presented for the convenience of the reader are 25-cycle data

for sizes AA, C, and D generated by tests conducted by Rayovac. However, those results were

not independently verified. 

The size AAA 25-cycle data indicate that for a load of 10 ohms and an endpoint voltage of 0.9

volts, simulating toys and electrical motors, the Renewal® batteries provided 1.6 hours of service

at the 25th cycle, or 20.8 percent of the energy capacity of a size AAA non-rechargeable alkaline

battery. Furthermore, the cumulative energy capacity after 25 cycles was 57.0 hours of service,

or 740 percent of the energy capacity of a size AAA non-rechargeable alkaline battery. In other

words, after 25 cycles, the size AAA Renewal® batteries provided the energy of about 7.5 nonrechargeable alkaline batteries, with about 21 percent of the energy available on the first cycle

still available on the 25th cycle. 
20

Table 3-5. Renewal® vs. Primary Alkaline Performance (Hours of Service)

Tracor - 5 Cycle Continuous Tests 25 Cycle Continuous Tests

Size Load 

(ohm)

EndPt.

(Volt)

Primary

Alkaline

 Hours 

%

Renewal®

Initial

 Hours 

%

Renewal ® 5th

Cycle

 Hours %

5 Cycle Cumulative

 Hours 

%

Std.

Dev.

 (%)+

25th Cycle

Hours %

25 Cycle Cumulative 

 Hours %

D 2.2 0.8 16.4 100 14.7 89.6 9.7 59.1 53.4 325 66 6.6* 40.2* 233.2* 1380*

D 3.9 0.9 34.5 100 27.8 80.1 15.4 44.6 104.1 302 30 ----- ------- --------- -----------

D 39 0.9 534.5 100 370.

4

69.3 86.3 16.1 916.9 172 35 ----- ------- --------- -----------

C 3.9 0.8 17.7 100 14.4 81.4 10.1 57.1 57.6 325 21 5.5* 29.4* 202.4* 1190*

C 6.8 0.9 33.5 100 25.2 75.0 17.6 52.5 106.0 316 7 ----- ------- --------- -----------

C 39 0.9 241.4 100 173.

0

71.7 108.3 44.9 636.0 263 36 ----- ------- --------- -----------

AA 3.9 0.8 5.3 100 4.0 75.5 2.2 41.5 14.6 275 8 1.3* 24.5* 52.0* 980*

AA 10 0.9 16.7 100 12.7 76.0 6.9 41.3 45.4 272 19 ----- ------- --------- -----------

AA 75 0.9 155.6 100 113.

3

72.8 57.6 37.0 389.7 250 7 ----- ------- --------- -----------

AAA 5.1 0.9 3.12 100 1.46 46.8 1.08 34.6 6.28 201 8 ----- ------- --------- -----------

AAA 10 0.9 7.7 100 4.0 51.9 2.9 37.7 16.3 212 49 1.6#20.8#57.0#740#

AAA 75 0.9 67.2 100 47.0 69.9 26.7 39.7 172.9 257 6 -----

-

------- --------- ---------

Note: Results reported as average of four measurements. “Percent” refers to percentage of primary alkaline capacity. 

+ largest standard deviation of five individual cycles, expressed as percent of mean.

* Rayovac-generated data, not independently verified by Tracor. 

# Tracor-generated 25-cycle test data.
1.40

1.902.402.903.403.904.404.905.40

0 5 10 15 20 25 30

Cycles

Hours to Endpoint Rayovac Tracor A Tracor B Tracor D

Tracor E

Load: 10.0 OhmsCutoff Voltage: 0.9 V

21

Figure 3-1. Size AAA Renewal® Capacity Fade Trends
22

3.5. Summary

This project focused on verifying the independent performance data previously collected as part

of the DTSC certification that met desired data quality objectives, including national versus

state-only applicability and quality assurance/quality control standards. Independently

generated data provided both five-cycle and 25-cycle performance data, as expressed by initial

and cumulative energy capacity in hours of service and as percent of non-rechargeable alkaline

batteries. The five-cycle data were for sizes AAA, AA, C, and D batteries, whereas the 25

cycle-data were independently generated for size AAA only. Five cycle tests were conducted

for 12 of the 16 ANSI tests modeling consumer applications such as toys, portable lighting,

transistor radios, and portable audio equipment. The following performance characteristics

were verified:

The initial capacity of the Renewal® batteries, as compared to non-rechargeable alkaline

batteries of the same size, in high-drain tests, was as follows: Size AAA: 4.0 hours (51.9%),

size AA: 4.0 hours (76.0%), size C: 14.4 hours (81.4 %), and size D: 14.7 hours (89.6%). 

After five cycles, for sizes AAA and AA, the Renewal® batteries produced cumulative hours of

service that ranged between that produced by two and three non-rechargeable alkaline batteries

of the same size. For sizes C and D, the Renewal batteries produced cumulative hours of

service that ranged between that produced by two and four non-rechargeable alkaline batteries

of the same size.

After 25 cycles, for size AAA, the Renewal® batteries produced cumulative hours of service

that ranged between seven and eight non-rechargeable alkaline batteries of the same size: 57.0

hours versus 7.7 hours. (Sizes AA, C, and D produced similar results in 25-cycle tests reported

by Rayovac, but those tests were not independently verified.) 

3.6. Conclusions

The Renewal® System batteries, under controlled laboratory conditions, using ANSI tests

modeling consumer applications, after five cycles, provided energy (measured as cumulative

hours of service) equivalent to that produced by two to three non-rechargeable alkaline batteries

of the same size for sizes AAA and AA, and produced energy equivalent to that between two

and four non-rechargeable alkaline batteries of the same size for sizes C and D. Similarly, for

25 cycles of size AAA, energy equivalent to that between seven and eight non-rechargeable

alkaline batteries, was produced. Therefore, the Renewal® System can reduce the number of

batteries used, and the number of batteries disposed. 
23

Section 4

 Toxicity Characteristic Leaching Procedure (TCLP) Tests

4.1. Introduction

Pollution can be prevented by either reducing the amount of waste generated or reducing its risk

or hazard to humans or the environment before it is generated. The previous section provided

performance data related to the life expectancy of the batteries, and thus the amount of waste

generated. This section provides data related to the toxicity of the batteries.

4.2. Sampling and Analyses

This section discusses the sampling and chemical analyses performed as part of the verification

effort. Renewal® batteries were subjected to U.S. tests for soluble metals content. The purpose

of the tests was to determine if the Renewal® batteries posed any potentially significant risk to

human health or the environment. 

4.2.1. Background

. 

The TCLP is a modified form of EPA’s previous hazardous waste extraction procedure, the

Extraction Procedure (EP) test. The TCLP is required for federal Resource and Conservation

Recovery Act (RCRA) hazardous wastes in two instances: Determination of compliance with

EPA Land Disposal Restriction regulations, and for waste classification of RCRA hazardous

wastes (12). The TCLP is intended to simulate the leaching of constituents from wastes

disposed in a municipal or sanitary waste landfill. This test has been shown to be more

reproducible, and, for certain waste constituents, more aggressive than the EP toxicity test (that

is, higher concentrations are extracted with the TCLP). The TCLP is Method 1311 in “Test

Methods for Evaluating Solid Waste, Physical/Chemical Methods,” EPA Publication SW-846

(13).

For RCRA hazardous waste toxicity characterization, the TCLP must be used; total metals

concentrations are not used by the U.S. government for characterization purposes. The TCLP

is used in conjunction with applicable analytical methods to determine if the eight metals and

six pesticides previously regulated as “EP Characteristic” wastes, as well as more than 25

organic compounds, are present at or above hazardous levels. These contaminants and their

maximum concentrations are listed in Section 261.24 of Title 40, Code of Federal Regulations. 

4.2.2. Sample Preparation

Sample preparation is a critical step in analyzing batteries for metals content. Obtaining a

representative sample can be very difficult due to metal volatilization, loss through adherence to

sampling equipment, and the nonhomogeneous structure of the batteries. Also, standard sample

preparation techniques can be hazardous to personnel and labor intensive, due to the need to
24

separate the electrolyte from the case and grind the materials. Moreover, there is no national

standard for preparing batteries for analyses. Rayovac submitted its internal sample preparation

procedures for batteries for review and comment. The procedure was reviewed by NRMRL,

OPPTD and HML. The procedure is summarized below (14):

The entire battery or cell is weighed. Rayovac recommends always using one or more 

entire cells or batteries because metals are not uniformly distributed throughout the

cells. Then the batteries are frozen using liquid nitrogen so that the internal components

become brittle for easier processing and to minimize volatilization. The batteries are

then crushed to pass a 9 mm sieve, sized as necessary, and placed in sample jars for

analyses. Sample pieces are removed from tools and combined with the rest of the

sample. Tools are cleaned with isopropyl alcohol between analyses.

4.2.3. TCLP Analyses

Renewal® Batteries were purchased, prepared, and analyzed by Minnesota Valley Testing

Laboratories (MVTL) of Oak Creek, Wisconsin, in June, 1998. Four samples were obtained. 

The samples were prepared using Rayovac’s “Cell Preparation for Testing Primary Whole

Cells and Batteries.” TCLP extraction was performed using SW-846 Method 1311, acid

digestion using SW-846 Method 3010A, mercury digestion and analysis using SW-846 Method

7470, and analyses for metals using SW-846 Method 6010A. Chain-of-Custody requirements

were followed, as were standard Quality Assurance/Quality Control requirements from SW846. 

4.3. Results

The results are reported in Table 4-1. All non-detect results are reported as <[detection limit]. 

Only barium and silver had results over the detection limit. Refer to Appendix C for the

Laboratory Final Report, the QA/QC Analysis Report, and Chain of Custody Forms. 
25

Table 4-1. Toxicity Characteristic Leaching Procedure Results

As Ba Cd Cr Pb Hg 

mg/l limit 5.0 100.0 1.0 5.0 5.0 0.2 

SAMPLE DESCRIPTION D004 D005 D006 D007 D008 D009 98C126 AAA-SIZE <0.036 0.35 <0.0068 <0.065 <0.029 <0.0083 98C125 AA- SIZE <0.036 0.35 <0.0068 <0.065 <0.029 <0.0083 98C121 C-SIZE <0.036 <0.29 <0.0068 <0.065 <0.029 <0.0083 98C124 D-SIZE <0.036 <0.29 <0.0068 <0.065 <0.029 <0.0083 

SAMPLES1 44 4 4 4 4 

DETECTION 0.036 0.29 0.0068 0.065 0.029 0.0083 MAXIMUM2 <0.036 0.35 <0.0068 <0.065 <0.029 <0.0083 

MAX % OF 0.7% 0.3% 0.7% 1.3% 0.6% 4.2% 

Renewal® sample preparation and testing by MVTL Laboratories, Inc. Oak Creek, Wisco

Notes: 1. One sample per battery size2. Results are reported as maximums without statistical analyses because nearly all analyses resulted in non-d3. Regulatory Limits Reference - U.S. Code of Federal Regulations, Title 40, Section 261.24, 1997. 
26

4.4. Summary

Four samples of batteries were independently collected and analyzed. TCLP results for all

metals were below their respective EPA regulatory limits. Only barium and silver were found

above the detection limits; barium was found at two orders of magnitude below its regulatory

limit, while silver was found at one order of magnitude below its regulatory limit. Statistical

analyses are not relevant or presented because only four of 32, or 12.5 percent, of the analyses

yielded results above the detection limit. These results are consistent with results reported by

Rayovac; however, those results were not independently verified.

4.5. Conclusions

No potentially significant impacts due to leaching of federally regulated toxic metals were

identified. All metals were at least one order of magnitude below their respective regulatory

threshold.
27

Section 5

Cost Estimates

This section presents current typical retail costs for Rayovac primary alkaline and Renewal®

batteries, and for charging units. Then, as an example, the costs of the Renewal ® System,

using the independently verified battery life data for 25 cycles of size AAA batteries, are

compared to the cost of the equivalent number of primary alkaline batteries. 

Table 5-1 presents typical 1998 retail prices for Rayovac alkaline and Renewal® batteries, and

power station charging units. Table 5-2 presents costs for various amounts of Rayovac batteries

and charging units. Prices were verified by telephoning and visiting two retailers in the

Sacramento, California, area: Target and Wal-Mart. Both retailers were selling Rayovac

products within the ranges specified in Rayovac-supplied literature. 

As an example, the cost for a PS1 charger and a package of four size AAA Renewal® batteries

is approximately $16, while the cost for a four-pack of size AAA alkaline batteries is $4. From

the verified data over 25 cycles, the cumulative energy capacity of the Renewal® batteries is

approximately equivalent to seven alkaline batteries. Therefore, using the Renewal® batteries

saves purchasing seven packages of alkaline batteries for a savings of $28. Subtracting the cost

of the Renewal® charger and batteries nets a savings of $12, minus the cost of electricity for

recharging. If the PS3 charger was purchased instead of the PS1 charger, the cost would be

about $26 instead of $16, and there would be a net savings of $2. (While the PS3 charger is

more expensive, it will charge more types and quantities than the PS1, thus providing more

flexibility.) Rayovac estimates the life expectancy of the chargers to be five years, but this was

not verified. As will be shown below, the cost to charge the batteries is negligible. 

The cost of electricity to charge the batteries can be estimated as follows: On average, three to

five hours of charging are required. The PS3 charging unit is rated at 12 watts, with an average

current of 570 milliamperes supplied to four parallel charging circuits. As a conservative

estimate, five hours at 12 watts is 60 watt-hours, or 0.060 kilowatt-hours. A survey of

residential rate schedules for Southern California Edison, Pacific Gas & Electric, and the

Sacramento Municipal Utilities District indicates that the highest price for residential electricity

in California is about $0.12 per kilowatt-hour, so five hours is $0.0072, or roughly a penny. For

25 charges, the cost is about $0.18, or about three percent of the cost of the four-pack of

Renewal® batteries. 

Actual performance and cost savings depends on the types of batteries, chargers, applications,

user practices affecting the number of cycles and depth of discharge, and local cost of

electricity.
28

Table 5-1. Typical Rayovac Retail Prices (Source: Rayovac, November 1998)

BATTERY

SIZE

BATTERIES

PER

PACKAGE

TYPICAL RETAIL PRICES/PACKAGE

PRIMARY ALKALINE RENEWAL

D 2 $2.19 - $2.79 $4.99 - $5.99

C 2 $2.19 - $2.79 $4.99 - $5.99

AA 4 $2.57 - $2.99 $5.99 - $6.99

AAA 4 $2.57 - $2.99 $5.99 - $6.99

TYPICAL RETAIL PRICES FOR RAYOVAC POWER STATIONS (CHARGERS):

PS1 (AA AND AAA SIZE RENEWAL BATTERIES): $ 9.99

PS3 (D, C, AA, AND AAA SIZE RENEWAL BATTERIES): $19.99
29

Table 5-2. Costs for Various Amounts of Rayovac Batteries (Source: Rayovac, November 1998)

BATTERY SIZE

RAYOVAC RENEWAL BATTERIES, POWER STATION RAYOVAC PRIMARY 

NO. OF

PACKAGES OF

BATTERIES

PRICE OF

POWER

STATION

PRICE PER

PACKAGE,

BATTERIES

TOTAL PRICE,

BATTERIES PLUS

POWER STATION

NO. OF PACKAGES

OF BATTERIES

D, C

1 $19.99 $4.99

$5.99

$24.98$25.98

7 

2 $19.99 $4.99

$5.99

$29.97$31.97

14 

3 $19.99 $4.99

$5.99

$34.96$37.96

21 

4 $19.99 $4.99

$5.99

$39.95$43.95

28 

5 $19.99 $4.99

$5.99

$44.94$49.94

35 

AA, AAA

1 $ 9.99 $5.99

$6.99

$15.98$16.98

7 

2 $ 9.99 $5.99

$6.99

$21.97$23.97

14 

3 $ 9.99 $5.99

$6.99

$27.96$30.96

21 

4 $ 9.99 $5.99

$6.99

$33.95$37.95

28 

5 $ 9.99 $5.99

$6.99

$39.94$44.94

35 
30

Section 6

Application Assessments

Typical consumer applications of household batteries include toys and games, portable audio

equipment, cameras, sporting goods equipment, test equipment, personal care products, hearing

aids, portable data terminals, sub-notebook computers and personal digital assistants, watches,

flashlights, lanterns, and cordless or cellular phones. Sometimes the battery is a built-in part of

a consumer product; in those cases the battery may or may not be rechargeable. A portable

electric razor is one example of such a product where the built-in battery may be rechargeable.

The most common 1.5V batteries that come in standard sizes AAA, AA, C, or D are carbon

zinc, primary alkaline, and nickel cadmium (NiCd). Rechargeable Alkaline Manganese (RAM,

trade name Renewal®) batteries are now also available. The major criteria for battery selection

are the application, storage life (ability to hold charge during storage), capacity, rate capability

(maximum current), frequency of use, ease of disposal, and cost. The driving criterion is

application, or what device the battery will power. No one battery is the optimum choice for

every application. Household battery users should consult consumer product specifications and

battery selection criteria when evaluating what type of battery to choose.

In general, non-rechargeable alkaline batteries are good for applications which are single use

(e.g., disposable devices), require or desire high energy capacity (e.g., toys, portable stereos), or

long storage life (e.g., emergency lighting and communications). Renewal® batteries are

appropriate for applications that need high capacity, low self-discharge characteristics, and

rechargeability. Rechargeable alkalines are candidates for applications where non-rechargeable

alkalines are now used. However, rechargeable alkaline batteries such as the Renewal® System

batteries are a better choice if the devices are used frequently, use low to medium currents (150

- 400 mA for size AA), and have cutoff voltages of 0.9V or greater. Cutoff voltages lower than

0.9V may allow deep depth of discharge leading to undesirable fade capacity under conditions

of very low current and long time of use (e.g., clocks).

The Renewal® System is especially well suited for intermittent-discharge applications which

may not fully drain the batteries prior to each recharge because they do not experience

significant capacity fade under those conditions. When fully drained, Renewal® batteries

experience capacity fade -- the capacity of the cell will be lower in comparison to the previous

cycle. Thus, for example, they are appropriate for applications such as emergency lighting,

which may require long storage life; palm-held computers, cordless or cellular phones, and

electric razors, which may require intermittent use; and portable music devices and toys, which

require low to moderate discharge rates and high capacity.

The Rayovac Renewal® System is not appropriate for applications that require high current such

as portable electric power tools such as electric drills. Nickel-cadmium batteries are better

suited for such applications. NiCd batteries also are a good choice for applications requiring

high continuous currents (for example, currents above 250 mA when using size AAA, and
31

above 400 mA when using size AA batteries), many cycles, frequent use, and deep discharge.

Also, devices such as photoflashes and video camera recorders may require more current than

Renewal® batteries can deliver. NiCd batteries can be charged and discharged multiple times

(theoretically several hundred) and have a higher rate capability (maximum current) than both

primary alkaline and Renewal® batteries due to less internal resistance. 

Thus, NiCds are a good choice for high-current products such as power tools and notebook

computers. NiCds would not be a good battery choice for applications that require long shelf

lives, however, because they self-discharge over time when left in storage (approximately 1%

per day). NiCd batteries may also not be the best selection for applications that do not fully

discharge the battery. NiCd cells, if not fully discharged with each use, develop a memory

effect and may not charge back to the nominal voltage, which can shorten cycle life. NiCd

batteries can have a longer cycle life than either primary alkaline or Renewal® batteries if not

damaged due to overcharging or overheating. Thus, NiCds may not require replacement as

often as alkaline batteries, but require special handling for disposal or recycling because of

statutory requirements imposed due to their high toxicity.

An application such as an emergency flashlight that requires batteries to have a long storage life

would be best suited to primary alkaline or Renewal® batteries, which have longer storage lives

than NiCds, and are sold in a charged state. Primary alkaline and Renewal® batteries, because

of their relatively high capacity, are also suitable for equipment such as electronic games and

toys and portable cassette players, which do not require high currents to operate, but may be

frequently used for long periods of time. 

Renewal® batteries are basically appropriate for most of the applications as primary alkaline

batteries. However, because Renewal® batteries have a higher internal resistance than primary

alkalines, they may not perform as well as primary alkalines in applications that require high

continuous or pulse current loads, such as photo flashbulbs. Renewal® batteries also differ from

primary alkalines in that they have a slightly shorter storage life, lower energy capacity, and a

longer cycle life. Renewal® batteries, because they can be recharged, require disposal less often

than primary alkalines. 

In summary, primary alkaline batteries are good for applications such as single use (disposable

devices), those which require or desire high capacity (toys, portable stereos), or long storage life

(emergency lighting, communications). NiCds are a good choice for applications requiring

currents above 400 mA when using size AA batteries - other sizes have different maximum

continuous current limits. NiCds are also a good choice for applications which require many

cycles, frequent use, and deep discharge (portable power tools). Renewal® batteries in general

are candidates for most applications where primary alkaline batteries are now used. Renewal®

batteries are a better choice if the devices are used frequently, use low to medium current (150 -

400 mA for size AA), and have cutoff voltages of 0.9V or greater.
32

Section 7

References

1. “Environmental Technology Verification Program: Verification Strategy,” U.S.

Environmental Protection Agency, Office of Research and Development, Washington

DC, 20460, EPA/600/K-96/003, February 1997. 

2. “Hazardous Waste Technology Certification Program Evaluation Report: Rayovac

Rechargeable Alkaline Household Battery System,” California Department of Toxic

Substances Control, Office of Pollution Prevention and Technology Development,

April, 1998.

3. "Household Battery Waste Management Study: Final Report," Ernst & Young, prepared

for California Integrated Waste Management Board, March 31, 1992.

4. “1996-1997 OEM Designer’s Guide & Technical Data,” Rayovac Corporation, June

1996. 

5. Letter dated May 19, 1997 from Raymond L. Balfour of Rayovac Corporation to Terry

Escarda of DTSC, describing use of silver and lead.

6. Letter dated August 25, 1995 from Raymond L. Balfour of Rayovac Corporation to

Terry Escarda of DTSC, describing charging requirements and design.

7. “American National Standard (ANSI C18.2M-1991): Sealed Rechargeable (Secondary)

Nickel-Cadmium Cylindrical Bare Cells and Jacketed Batteries," American National

Standards Institute, New York, (October 1990).

8. “American National Standard (ANSI C18.1M-1992): Dry Cells and Batteries -

Specifications," National Electrical Manufacturers Association, (September 1992).

9. Letter dated October 10, 1995 from Raymond L. Balfour of Rayovac Corporation to

Terry Escarda of DTSC, enclosing “Renewal® Consumer Response,” Rayovac

Corporation, February 21, 1995.

10. "Chemical Principles, Third Edition," Dickerson, Gray, and Haight, The

Benjamin/Cummings Publishing Company, Menlo Park, California, 1979. 

11. Personal Communication, Richard Walk, Director, Tracor Battery Testing Center, and

Terry Escarda of DTSC, May 5, 1997.
33

12. “HML User’s Manual”, California Department of Toxic Substances Control, Hazardous

Materials Laboratory, Berkeley, California, October 31, 1995. 

13. “Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, Third Edition,”

SW-846, U.S. Environmental Protection Agency, Office of Solid Waste and Emergency

Response, Washington, DC 20460, November 1986. 

14. “Cell Crushing Preparation for Testing Whole Primary Alkaline Batteries,” R.D.

Donaldson, Rayovac Corporation, 1993.

Availability of this Report

 Copies of the public Verification Report (EPA/600/R-99/005VS) and Verification

Report (EPA/600/R-99/005) are available from the following:

 1. US EPA / NSCEP

P.O. Box 42419

Cincinnati, Ohio 45242-2419

Web site: http://www.epa.gov/etv/library.htm (electronic copy)

 http://www.epa.gov/ncepihom/ (hard copy)

 2. Department of Toxic Substances Control

Office of Pollution Prevention and

 Technology Development

P.O. Box 806

Sacramento, California 95812-0806

Web site: http://www.dtsc.ca.gov/sppt/opptd/etv/txppetvp.htm