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 to ONR that 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 - Dangerous Goods Safety Advice - Rating: GREEN
- Transport - Incidents, Events and Reporting processes - Rating: AMBER
- Transport - Management Systems - Rating: AMBER
- Transport - Radiation Protection Advisor - Rating: GREEN
- Transport - Radiation Protection Programme - Rating: GREEN
- 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 some DRS railheads.
On 15/11/24, DRS reported an incident 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 EnerMech were not compliant with other legal requirements.
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:
- served, in accordance with the Enforcement Management Model and Enforcement Policy Statement, an enforcement letter (ONR-EL-24-46 - Enforcement Letter EnerMech Limited - February 2025.DOCX) to EnerMech.
- raised a Level 3 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.