THIS COMPLAINT IS ISSUED AGAINST DANIEL A. HARTWIG FOR FAIL- URE TO VISUALLY INPSECT TO IDENTIFY ACBM AND FAILURE TO IDENTIFY FRIABLE AND NON-FRIABLE ACM IN HOMOGENOUS AREAS THE RESPONDENT, HARTWIG, FAILED TO INCLUDE SUSPECTED ACBM MATERIAL, IDENTIFIED BY THE EPA INSPECTOR, IN THE INSPECTION RECORDS OR MANAGEMENT PLAN.