Lisa M. Satterfield didn't figure she'd wind up suing the Environmental Protection Agency when she began an assignment for her class at the University of Maryland Law School.
But then she discovered that the federal regulations she wanted to study had never been issued. So she teamed up with the Sierra Club Legal Defense Fund and notified the EPA of their intent to sue the agency to enforce the 1990 Clean Air Act.
As part of the act, Congress ordered the EPA to regulate chlorofluorocarbons and other chemicals that are destroying the Earth's ozone layer.
CFCs released on the ground drift into the upper atmosphere, where they break down the ozone molecules that block out harmful ultraviolet rays from the sun.
Scientists warn that depletion of the ozone layer will increase skin cancers and other diseases and could harm plants and other organisms.
Prodded by new measurements showing a dramatic buildup of ozone-depleting chemicals in the stratosphere over the North Pole, the Bush administration announced last week that it would halt CFC production by 1995, five years earlier than required by an international treaty.
Ms. Satterfield was looking for EPA rules intended to promote the recycling and safe disposal of CFCs used in household refrigerators, meat lockers, vending machines and a host of other commercial and industrial coolers.
But when she called the EPA to ask about the rules, which were supposed to take effect Jan. 1, she said an official told her the agency "hadn't even proposed" them much less issued the final regulations.
"I thought that was pretty ridiculous," said Ms. Satterfield, who is president of the Maryland Environmental Interest Group, a law school club.
Ms. Satterfield and a lawyer for the Sierra Club wrote EPA Administrator William K. Reilly, accusing him of violating the law. The letter threatens suit unless the agency issues the rules in final form by April 11. Under the Clean Air Act, citizens seeking to enforce it must give 60 days notice before suing.
EPA officials say they plan to propose the CFC recycling regulations sometime in April. They say they have been busy on other rules to phase out production of CFCs and to recycle ozone-depleting coolants used in car and truck air conditioners.
"We're late. I'm not trying to avoid that," said Stephen Seidel, deputy director of EPA's global change division. Even without the regulations, Mr. Seidel said, the Clean Air Act prohibits anyone from knowingly releasing CFCs into the atmosphere after July 1. But the law by itself, with no regulations to clarify it, may be confusing, he acknowledged.
A United Nations panel estimates that about 130,000 tons of CFCs are in use worldwide in household appliances and commercial and industrial refrigeration equipment.
Substantial amounts of ozone-depleting chemicals are released from leaking cooling equipment or during the servicing, repair and disposal of appliances and refrigeration units, experts say. It once was common practice to vent the coolant gases during servicing.
The reasons for recycling are economic as well as environmental, Ms. Satterfield said. Industry and government are working on a variety of CFC substitutes, but all existing refrigeration units may not work with the new coolants.
Replacing or retrofitting existing refrigeration units to accommodate new coolants could cost $3.4 billion, the U.N. panel estimates, so conserving the existing CFC supply would spare users from having to make huge investments in new equipment all at once.
Ms. Satterfield's concern about the planet is not just for a grade. The 31-year-old single mother said she is working with the University's Center for Global Change in College Park on global warming issues, and she plans a career in international environmental affairs.