FAILURE TO IMMEDIATELY REPORT THE RELEASE OF EXTREMELY HAZARDOUS SUBSTANCES FROM THE C AVENUE FACILITY TO THE LEPC AND TO THE SERC CONSTITUTES A VIOLATION OF THE NOTIFICATION REQUIREMENT OF SECTION 304(A) OF EPCRA. FAILURE TO PROVIDE WRITTEN FOLLOWUP EMERGENCY NOTICE CONCERNING THE RELEASE DESCRIBED ABOVE IN THIS COMPLAINT CONSTITUTES A VIOLATION OF SECTION 304(C) OF EPCRA.