EPA/600/R-99/005VS
                                                                    MARCH 1999
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
               Office of Research and Development
                     Washington DC 20460             f§)C3I/EPA I
  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 RenewalŪ.
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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 RenewalŪ 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 RenewalŪ 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 RenewalŪ 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 RenewalŪ batteries'
       performance to that of Rayovac's non-rechargable alkaline batteries;

 2)    determine what levels of federally regulated toxic metals might leach from the RenewalŪ
       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, 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 RenewalŪ 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 RenewalŪ 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 RenewalŪ
Rechargeable Alkaline Household Battery System" (EPA/600/R-99/005)."

VERIFICATION OF PERFORMANCE

The observed performance characteristics of the RenewalŪ System include the following:

•      Energy Capacity:

       The initial energy capacity of the RenewalŪ 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 RenewalŪ  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 RenewalŪ  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
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. RenewalŪ 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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Results of the verification show that the RenewalŪ 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 RenewalŪ 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 RenewalŪ 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., Chief         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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                  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)

             1. 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)	
                                                                                        MARCH 1999

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