TERRA INDUSTRIES INC., FAILED TO IMMEDIATELY REPORT A RELEASE OF AMMONIA TO THE NRC AND SERC, FAILED TO TIMELY SUBMIT A WRITTEN FOLLOW UP REPORT TO THE SERC, AND FAILED TO SUBMIT A TIER II REPORT TO THE SERC AND CROOKSTON FIRE DEPARTMENT FOR THE 1997 CALENDAR YEAR. COMPLAINT ALLEGES SEVERAL VIOLATIONS OF CERCLA AND EPCRA FROM A AUGUST 28, 1998 RELEASE OF AMMONIA.