Executive summary
Date(s) of inspection:
January 2025
Aim of inspection
Direct Rail Services Limited (DRS) undertake rail carriage for various nuclear sector dutyholders including EDF Energy Nuclear Generation Limited (EDF), Nuclear Waste Services, Nuclear Restoration Services, Sellafield Limited and the Ministry of Defence. DRS contract the services of EnerMech Limited (EnerMech - a lifting / crane maintenance operator responsible for loading / unloading the Mk A2 AGR transport flask) at DRS railheads.
On 15/11/24, DRS reported an incident (INF-4597) to ONR - EnerMech did not have an appointed radiation protection adviser (RPA) and radiation risk assessment (RRA) as required by IRR17.
ONR conducted preliminary enquiries with EnerMech and DRS in accordance with ONR-ENF-GD-005 to ascertain: the nature of the non-compliances; what corrective actions have taken place to reduce the risk and compliance gap; whether future improvements are required, and; if enforcement action is necessary.
Subject(s) of inspection
- Transport - Incidents, Events and Reporting processes - Rating: AMBER
- Transport - Management Systems - Rating: RED
- Transport - Training and Competence - Rating: AMBER
Key findings, inspector's opinions and reasons for judgement made
Direct Rail Services Limited (DRS) undertake rail carriage for various nuclear sector dutyholders including EDF Energy Nuclear Generation Limited (EDF), Nuclear Waste Services, Nuclear Restoration Services, Sellafield Limited and the Ministry of Defence. DRS contract the services of EnerMech Limited (EnerMech) at certain DRS railheads.
On 15/11/24, DRS reported an incident (INF-4597) to ONR that EnerMech (a lifting / crane maintenance operator responsible for loading / unloading the Mk A2 AGR transport flask at DRS railheads) did not have an appointed radiation protection adviser (RPA) and radiation risk assessment (RRA) as required by IRR17. During preliminary enquiries, I found that both EnerMech and DRS were not compliant with other legal requirements relating to the carriage of Class 7 dangerous goods.
Due to the shortfalls identified in the preliminary enquiries, an improvement notice (ONR-IN-24-13) has been served to DRS.
Conclusion
Based on:
- the actions taken by DRS and EnerMech to reduce the immediate risks and compliance gaps
- my review of the compliance gap analysis provided by INS
I consider it acceptable for both organisations to continue Class 7 transport rail operations.
Following the enquiries, I:
- raised a Level 2 regulatory issue (Regulatory Issue: Information: Transport of Class 7 dangerous goods in contravention of CDG09, Regulation 5 - Power Apps) to support a return to compliance.
I will consider the relationships between DRS, INS and NTS during future dutyholder engagements, and set out a strategy for ongoing regulatory inspection and oversight.