EPA/600/R-99/005VS 

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®. 

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. 

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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. 

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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. 

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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., Chief 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. 

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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) 

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