ANDRE DAUGEVIETIS HAS BEEN CHIEF COUNSEL TO THE CHROMIUM MACT WORKGROUP. COMPLAINT ALLEGES THAT INTAGLIO VIV-COLOR VIOLATED THE CHROME PLATING NESHAP AT ITS GRAPHIC ARTS FACILITY IN MIDDLETOWN, OHIO. SPECIFICALLY, THE COMPLAINT ALLEGES THAT INTAGLIO VIOLATED THE EMISSIONS LIMIT FOR CHROMIUM; FAILED TO CONDUCT A TIMELY, INITIAL PERFORMANCE TEST; FAILED TO PRE PARE A TIMELY O&M PLAN; FAILED TO MONITOR AND RECORD PRSSURE PRESSURE DROP ACROSS THE COMPOSITE MESH PAD SYSTEM; AND FAILED TO MAINTAIN RECORDS OF MONITORING.