TSA allows each airline to make their own policy about whether or not they will accept non-spillable batteries in checked luggage. In 2004, Delta

totally refused to accept them at the airport and we had to FedEx them.
In 2005 Northwest

had no problem taking our 12 batteries in checked luggage. This year we have gotten conflicting answers from AirTran

so we sent some in the crate, we'll ship some and we will see what happens at the airport.