United States
Environmental Protection
Agency
Office of Research and
Development
Washington, DC 20460
EPA/600/R-99/005
March 1999
Environmental Technology
Verification Report
Rechargeable Alkaline
Household Battery System
Rayovac Corporation, Renewal®
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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
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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.
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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.
in
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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, Tracer 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.
IV
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Office of Research and Development
Washington DC 20460 QCsl/EPAl
vvEPA
California Environmental Protection Agency
ENVIRONMENTAL TECHNOLOGY VERIFICATION STATEMENT
TECHNOLOGY TYPE: RECHARGEABLE ALKALINE HOUSEHOLD BATTERY
SYSTEM
APPLICATION:
1.5 VOLT BATTERIES IN STANDARD SIZES AAA, AA, C,
ANDD
TECHNOLOGY NAME: RENEWAL8
COMPANY:
ADDRESS:
PHONE:
FAX:
RAYOVAC CORPORATION
601 RAYOVAC DRIVE
MADISON, WISCONSIN 53711-2497
P.O BOX 44960
(608) 275-4584
(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®.
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MARCH 1999
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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, sub-
notebook 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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MARCH 1999
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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, Tracer, Inc., a contractor with an independent battery testing facility, conducted several
series of American National Standards Institute (ANSI) energy capacity tests. Tracer 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 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.
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MARCH 1999
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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
REGULATORY
LIMIT
MAXIMUM
DETECTED
Arsenic
5.0
O.036
Barium
100.0
0.32
Cadmium
1.0
O.0068
Chromium
5.0
<065
Lead
5.0
<.029
Mercury
0.2
<.0083
Selenium
1.0
<.39
Silver
5.0
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 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 per pack of four 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 size of batteries and type and number of chargers purchased.
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MARCH 1999
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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 non-
rechargeable 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
E. Timothy Oppelt
3/26/99
E. Timothy Oppelt Date
Director, National Risk Management
Research Laboratory
Office of Research and Development
United States Environmental
Protection Agency
Original Signed By
James. T. Allen, Ph.D.
3/19/99
James T. Allen, Ph.D. Date
Chief, Office of Pollution Prevention
And Technology Development
Department of Toxic Substances Control
California Environmental 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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MARCH 1999
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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. USEPA/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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TABLE OF CONTENTS
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. ANSIEnergy Capacity Tests 13
3.2.2. Modified ANSIEnergy 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
XI
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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 Station™ 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 — Tracer Performance Laboratory Report
Appendix C — TCLP Laboratory Report
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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
1 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
Xlll
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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, Tracer 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
1
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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 DISC 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 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. (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
REGULATORY
LIMIT
MAXIMUM
DETECTED
Arsenic
5.0
<0.036
Barium
100.0
0.32
Cadmium
1.0
<0.0068
Chromium
5.0
<.065
Lead
5.0
<.029
Mercury
0.2
<.0083
Selenium
1.0
<.39
Silver
5.0
0.19
* Limits are US EPA TCLP regulatory thresholds, 40CFR261.24, 1997
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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.
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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 commercial-
ready 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
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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.
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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-rechargeableV
• 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 non-
rechargeable (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
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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.
-------
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
Carbon-Zinc-
Silver Oxide
Zinc Air
Lithium
D, C, AA, AAA,
9V
D, C, AA, 9V
Button
Button
Button^'
Manganese Dioxide
Carbon
Silver Oxide
Atmospheric
Oxygen
Manganese Oxide
Zinc
Zinc
Zinc
Zinc
Lithium
Potassium
Hydroxide
Ammonium
Chloride or Zinc
Chloride
Potassium
Hydroxide
Potassium
Hydroxide
Organic Solvent
Toys, games, clocks, electronic flashes, tape recorders,
calculators, flashlights, radios, smoke alarms, cameras
Toys, games, flashlights, radios, tape recorders
Watches, calculators, hearing aides, cameras
Hearing aids, pagers
Cameras, calculators, pacemakers, watches
Secondary Batteries
Nickel-
Cadmium
Nickel-Metal
Hydride
Rechargeable
Alkaline
Manganese
D, C, AA, AAA,
9V
Same as Nickel-
Cadmium
D, C, AA, AAA
Nickel Oxide
Nickel
Oxyhydoxide
Manganese Dioxide
Cadmium
alloys or rare
earth metals-
Zinc, Lead
Potassium
Hydroxide
Potassium
Hydroxide
Potassium
Hydroxide
Power hand tools, portable vacuums, computers, fire and
burglar alarms, electric razors, cordless and cellular
telephones, toys, games, video cameras, electric toothbrushes
Same as Nickel-Cadmium
Same as alkaline
oo
a/
, .Includes "General Purpose" and "Heavy Duty" batteries.
~ 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.
-------
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, sub-
notebook 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.
-------
FIGURE 2-1. Rayovac Renewal® Batteries
10
-------
2.2. Renewal Charging Devices
The Rayovac Renewal® charging device is known as a Power Station™. The Power Station™
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 current-
limiting 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)
11
-------
FIGURE 2-2. Rayovac Charging Unit (PS3)
12
-------
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 Tracer Battery Technology Center, an independent testing facility.
3.2. Performance Measures
There are many ways of measuring a battery's performance, including initial capacity (Ampere-
hours 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
13
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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 CIS. 1M-1992 Specifications, Alkaline Manganese Dioxide, Size AAA
LOAD (Ohms)
3.6
5.1
10
75
TEST
SCHEDULE
15 SEC/MIN,
24HRS
4 MIN / HR,
8 HRS / DAY
1HR/DAY
4 MRS/DAY
END
POINT(Volts)
0.9
0.9
0.9
0.9
TYPICAL
PERFORMANCE
INITIAL
450
PULSES
125 MIN
5.5 HRS
48 HRS
12 MONTHS
405 PULSES
112 MIN
5 HRS
43 HRS
TYPICAL USE
PULSE TEST
(PHOTO)
PORTABLE
LIGHTING
PERSONAL TAPE
RECORDER &
CASSETTE
PLAYER
TRANSISTOR
RADIO
14
-------
Table 3-2. ANSI C18. 1M-1992 Specifications, Alkaline Manganese Dioxide, Size
AA
LOAD
(Ohms)
1.8
3.9
10
75
TEST
SCHEDULE
15SEC/MIN,
24 MRS
1HR/DAY
1 HR/ DAY
4 MRS/DAY
END POINT
(Volts)
0.9
0.8
0.9
0.9
TYPICAL
PERFORMANCE
INITIAL
360
PULSES
5 MRS
13.5
MRS
115
MRS
12 MONTHS
324
PULSES
4.5
MRS
12
MRS
104
MRS
TYPICAL USE
PULSE TEST
(PHOTO)
MOTOR & TOYS
PERSONAL TAPE
RECORDER &
CASSETTE PLAYER
TRANSISTOR RADIO
Table 3-3. ANSI C18. 1M-1992 Specifications, Alkaline Manganese Dioxide, Size C
LOAD
(Ohms)
3.9
3.9
6.8
39
TEST
SCHEDULE
4 MIN/HR,
8HRS/DAY
1 HR / DAY
1 HR/ DAY
4 MRS/DAY
END POINT
(Volts)
0.9
0.8
0.9
0.9
TYPICAL
PERFORMANCE
INITIAL
830 MIN
14.5 MRS
24 MRS
160 MRS
12
MONTHS
737 MIN
13 MRS
22 MRS
144 MRS
TYPICAL USE
PORTABLE
LIGHTING
TOYS
TAPE RECORDER
TRANSISTOR RADIO
15
-------
Table 3-4. ANSI C18. 1M-1992 Specifications, Alkaline Manganese Dioxide, Size D
LOAD (Ohms)
2.2
2.2
3.9
39
TEST
SCHEDULE
4 MIN/HR,
8 MRS/DAY
1 HR/ DAY
1 HR/ DAY
4 MRS/DAY
END POINT
(Volts)
0.9
0.8
0.9
0.9
TYPICAL
PERFORMANCE
INITIAL
800 MIN
15.5 MIN
26 MRS
375 MRS
12
MONTHS
720 MIN
13.9 MIN
23.5 MRS
338 MRS
TYPICAL USE
PORTABLE
LIGHTING
TOYS
TAPE
RECORDER
TRANSISTOR
RADIO
3.2.2. Modified ANSI Energy Capacity Tests
ANSI standard CIS. 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 DISC 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.
16
-------
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. Tracer, 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 Tracer's
battery testing qualifications, refer to Appendix A.
In September 1995, Tracer 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 Tracer to verify their accuracy and
completeness. Comparing the results of the Tracer and Rayovac tests was complicated by the
fact that the tests which Tracer 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.
17
-------
The Tracer tests were more comprehensive in that Tracer used four batteries per test to analyze
performance variability, Tracer conducted tests for all of the ANSI recommended load and end-
point voltage specifications except for photoflashes, and Tracer used the Rayovac Power
Station™ 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, Tracer
only tested the first five cycles, whereas Rayovac performed 25 cycle testing.
In five of the 12 five-cycle tests conducted by Tracer, 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. Tracer
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, Tracer 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. Tracer completed those tests in October
1996.
3.4. Results
Table 3-5, presents the results, as averages, of the testing performed by Tracer to verify the in-
house testing conducted by Rayovac. Refer to Appendix B for the Tracer Data Sheets, which
include statistical variation information.
Table 3-5 presents Tracer's results as hours of service and as a percentage of the capacity of non-
rechargeable 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-of-
discharge than an cutoff voltage of 0.9 volts.
The initial capacity ranged from approximately 47 percent to 70 percent of that of non-
rechargeable 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 non-
rechargeable alkaline batteries of the same size. For size AA, the Renewal's initial capacity
18
-------
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 non-
rechargeable 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 non-
rechargeable 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 Tracer 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 non-
rechargeable alkaline batteries, with about 21 percent of the energy available on the first cycle
still available on the 25th cycle.
19
-------
Table 3-5. Renewal® vs. Primary Alkaline Performance (Hours of Service)
l| Tracer - 5 Cycle Continuous Tests
Size
D
D
D
C
C
C
AA
AA
AA
AAA
AAA
AAA
Load
(ohm)
2.2
3.9
39
3.9
6.8
39
3.9
10
75
5.1
10
75
EndPt.
(Volt)
0.8
0.9
0.9
0.8
0.9
0.9
0.8
0.9
0.9
0.9
0.9
0.9
n'rimary
. Jkaline
Hours
%
16.4
34.5
534.5
17.7
33.5
241.4
5.3
16.7
155.6
3.12
7.7
67.2
100
100
100
100
100
100
100
100
100
100
100
100
Renewal®
Initial
Hours
%
14.7
27.8
370.
4
14.4
25.2
173.
0
4.0
12.7
113.
o
6
1.46
4.0
47.0
89.6
80.1
69.3
81.4
75.0
71.7
75.5
76.0
72.8
46.8
51.9
69.9
Renewal ® 5th
Cycle
Hours %
9.7
15.4
86.3
10.1
17.6
108.3
2.2
6.9
57.6
1.08
2.9
26.7
59.1
44.6
16.1
57.1
52.5
44.9
41.5
41.3
37.0
34.6
37.7
39.7
5 Cycle Cumulative
Hours
%
53.4
104.1
916.9
57.6
106.0
636.0
14.6
45.4
389.7
6.28
16.3
172.9
325
302
172
325
316
263
275
272
250
201
212
257
Std.
Dev.
(%)+
66
30
35
21
7
36
8
19
7
8
49
6
25 Cycle Continuous Tests
25th Cycle
Hours %
6.6*
5.5*
1.3*
1.6*
-
40.2*
29.4*
24.5*
20.8*
25 Cycle Cumulative
Hours %
233.2*
202.4*
52.0*
57.0*
1380*
1190*
980*
740*
to
o
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 Tracer.
# Tracer-generated 25-cycle test data.
-------
5
5AO T-
4.90 -
4.40 --
3.90 -
3.40
2.90 --
2.40 --
1.90 --
1.40
Load: 10.0 Ohms
Cutoff Voltage: 0.9V
-•— Rayovac
• Tracor A
A Tracor B
Tracor D
-3K— Tracor E
Figure 3-1. Size AAA Renewal® Capacity Fade Trends
-------
3.5. Summary
This project focused on verifying the independent performance data previously collected as part
of the DISC 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.
22
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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
23
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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 SW-
846.
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.
24
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Table 4-1. Toxlclty Characteristic Leaching Procedure Results
SAMPLE
98C126
98C125
98C121
98C124
mg/1 limit
DESCRIPTION
AAA-SIZE
AA- SIZE
C-S1ZE
D-SKE
SAMPLES1
DETECTION
MAXIMUM2
MAX % OF
As
5.0
D004
<0.036
<0.036
<0.036
<0.036
4
0.036
<0.036
0.7%
Ba
100.0
D005
0.35
0.35
<0.29
<0.29
4
0.29
0.35
0.3%
Cd
1.0
D006
<0.0068
<0.0068
<0.0068
<0.0068
4
0.0068
<0.0068
0.7%
Cr
5.0
D007
<0.065
<0.065
<0.065
<0.065
4
0.065
<0.065
1.3%
Pb
5.0
D008
<0.029
<0.029
<0.029
<0.029
4
0.029
<0.029
0.6%
Hg
0.2
D009
<0.0083
<0.0083
<0.0083
<0.0083
4
0.0083
O.0083
4.2%
Se
1.0
D010
<0.39
<0.39
<0.39
<0.39
4
0.39
<0.39
39.0%
Ag
5.0
D011
<0.14
0.24
<0.14
0.23
4
0.14
0.24
4.5%
Renewal® sample preparation and testing by MVTL Laboratories, Inc. Oak Creek, Wisconsin
to
Ul
Notes:
1. One sample per battery size
2. Results are reported as maximums without statistical analyses because nearly all analyses resulted in non-detects
3. Regulatory Limits Reference - U.S. Code of Federal Regulations, Title 40, Section 261.24, 1997.
-------
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.
26
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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.
27
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Table 5-1. Typical Rayovac Retail Prices (Source: Rayovac, November 1998)
BATTERY
SIZE
D
C
AA
AAA
BATTERIES
PER
PACKAGE
2
2
4
4
TYPICAL RETAIL PRICES/PACKAGE
PRIMARY ALKALINE
$2. 19 -$2.79
$2. 19 -$2.79
$2.57 -$2.99
$2.57 -$2.99
RENEWAL
$4.99 -$5.99
$4.99 -$5.99
$5. 99 -$6.99
$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
28
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Table 5-2. Costs for Various Amounts of Rayovac Batteries (Source: Rayovac, November 1998)
BATTERY
1), C
AA, AAA
RAYOVAC RENEWAL BATTERIES, POWER STATION
NO. OF
PACKAGES OF
BATTERIES
1
2
3
4
5
1
2
3
4
5
PRICE OF
POWER
STATION
$19.99
$19.99
$19.99
$19.99
$19.99
$9.99
$ 9.99
$ 9.99
$ 9.99
$9.99
PRICE PER
PACKAGE,
BATTERIES
$4.99
S5.99
$4.99
$5.99
$4.99
$5.99
$4.99
S5.99
$4.99
S5.99
$5.99
$6.99
$5.99
$6.99
$5.99
S6.99
$5.99
S6.99
$5.99
$6.99
TOTAL PRICE,
BATTERIES PLUS
POWER STATION
$24.98
S25.98
$29.97
$31.97
$34.96
$37.96
$39.95
S43.95
$44.94
S49.94
$15.98
$16.98
$21.97
$23.97
$27.96
S30.96
$33.95
S37.95
$39.94
$44.94
PRIMARY ALKALINE BATTERIES
OF BATTERIES
7
14
21
28
35
7
14
21
28
35
PRICE PER
PACKAGE,
BATTERIES
$2.19
$2.79
$2.19
$2.79
$2.19
$2.79
$2.19
$2.79
$2.19
$2.79
$2.57
$2.99
$2.57
$2.99
$2.57
$2.99
$2.57
$2.99
$2.57
$2.99
TOTAL PRICE,
BATTERIES
$15.33
S19.53
$30.66
$39.06
$45.99
$58.59
$61.32
S78.12
$76.65
S97.65
$17.99
$20.93
$35.98
$41.86
$53.97
S62.73
$71.96
S83.72
$89.95
$104.65
to
MD
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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
30
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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.
31
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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 CIS. 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, Tracer Battery Testing Center, and
Terry Escarda of DTSC, May 5, 1997.
32
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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 USEPA/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/ (hardcopy)
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
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