Three EPA representatives inspected the City of Astoria Headworks on 7/11 and 7/15/2005. Based upon this inspection, EPA believes City of Astoria Headworks is in violation of the followiong risk managment program elements: Hazard Assessment, Process Hazard Analsyis, Operating Procedures, Training, Management of Change, Pre-startup Review, Incident Investigation, Compliance Audit, Employee Participation, Contractors and Updates.