On June 4, 2003, EPA Region III issued an administrative complaint to Lonza, Inc. ( Lonza ), seeking a total penalty of $39,939.00 for violations of Section 312 of EPCRA. Lonza failed to submit complete and accurate Emergency and Hazardous Chemical Inventory Forms to the Bureau of PENNSAFE (the designated SERC), the Montgomery County Office of Emergency Prepardness (the LEPC), and the local Fire Department of calendar years 1999, 2000, and 2001. The chemicals that Lonza failed to report include dibenzyltoluene, 2-butyl-5-chloro-4-formylimidazle, and benzyl chloride. Lonza's failure to report the presence of these chemicals at its facility had a deleterious effect upon the ability of federal, state, and local government entities to properly plan for chemical release at facilities in the community, and the public's ability to assess information concerning hazardous chemicals that are stored or otherwise present in their community