COUNT I: FAILURE TO IMMEDIATELY NOTIFY THE SERC FOLLOWING THE RELEASE OF AMMONIA (ANHYDROUS) IN EXCESS OF THE RQ, EPCRA SECTION 304(B), 42 U.S.C. SECTION 1004(B), AND 40 C.F.R. PART 355.40(B)(1). COUNT II: FAILURE TO PROVIDE, AS SOON AS PRACTICABLE, A WRITTEN FOLLOW-UP REPORT TO THE LEPC FOLLOWING THE RELEASE OF AMMONIA (ANHYDROUS) IN EXCESS OF THE RQ, EPCRA SECTION 304(C), 42 U.S.C. SECTION 11004(C), AND 40 C.F.R PART 355.40 (B)(3)).