FACILITY FAILED TO IMMEDIATELY NOTIFY THE NRC, SERC, AND LEPC OF A RELEASE OF 3,150 POUNDS OF AMMONIA, AND FAILED TO PROVIDE A WRITTEN FOLLOW UP REPORT TO THE SERC AND LEPC AS SOON AS PRACTICABLE AFTER THE RELEASE. SPECIFICALLY, THE COMPLAINT ALLEGES VIOLATIONS OF 103 (A) OF CERCLA, 304 (A) AND (C) OF EPCRA.