Expedited Settlement Agreement - 2/3/2005. Assessed penalty of $2,610. Failure to document written procedures which address emergency shutdown. Failure to document written operating procedures which address the following: Operating limits, Safety and health considerations. Failure to certify annually that the operating procedures are current and accurate and that procedures have been reviewed as often as necessary. Failure to indicate the necessary time period for a change as either permanent or temporary when implementing the management or change procedure.