OSHA has issued several PSM citations at a natural gas processing facility from an inspection that began in October 2014. This was an unannounced planned Chem NEP inspection. Of special note, these violations include issues with not having a Car Seal Program for valves within the relief path(s) of several relief devices. OSHA referenced ASME Section VIII, but did not specifically reference Appendix M-5 which contains the requirements for when a block valve is placed in the path of the relief system. PLEASE see my 2011 article, Car Seal Program and Relief Valves regarding how to comply with ASME Section VIII Appendix M- 5.