Final Disposal of NORM Waste in Qatar: Re-injection

The answer first

Final disposal of NORM waste in Qatar runs through article 12 of the rules attached to Decision 45 of 2013, and that article has four clauses. Waste must be conditioned before final disposal. The licensee must dispose of it in accordance with the laws and regulations in force, without exposing workers and the public or contaminating natural resources. Initial site selection rests on four criteria. And the method itself is the one set out in Annex 3, which names re-injection.

Three words first. NORM is naturally occurring radioactive material, which the rules define as material in which the concentration of radionuclides rises because of what people do to it. Conditioning is defined in the rules as the set of operations that turn radioactive waste into a form suitable for transport, storage or disposal, which may include changing its form, reducing its volume, containing it and providing extra wrapping for it. Disposal is defined as placing radioactive waste in a designated burial site, to specified specifications, to bury it permanently.

Read those last two definitions against Annex 3 and you will notice something. The definition of disposal speaks of a designated burial site and permanent burial. Annex 3 names one type of disposal, re-injection, and describes two ways of doing it, both of them downhole. We record that the wording of the definition and the wording of the annex are not the same, and we do not smooth it over by silence. What we do not say is that the annex permits surface landfill or incineration: it names neither.

The four clauses, one by one

Clause one is short and easy to skip, and it governs what you hand over. Waste containing NORM must be conditioned before the final disposal operation, so that it is done in a more suitable manner. Note that the clause gives a purpose and not a specification: more suitable, with no form, no volume and no container type named. The content of conditioning comes from the definition in article 1, which lists changing the form, reducing the volume, containing it and extra wrapping as things it may include.

Clause two is the obligation and the set of harms it guards against. It names three harms, and the last of them is the one people skim past. Disposal must not lead to exposure of workers and the public to radiation, nor to contamination of natural resources such as groundwater, nor to contamination of soil that may in future become residential or agricultural areas, even if it is at present remote or uninhabited. So a remote plot today is not a safe answer: the clause asks about the land's future, not only its present.

Clause three gives the criteria for initial site selection, and they are four: the risks, the technical feasibility, the cost, and public acceptance, which the clause then qualifies by requiring that nothing contravene the provisions of the law and these rules. Two observations. The clause itself calls them criteria for an initial selection, so they are a screen rather than a final decision. And the clause does not weight them, does not rank them and does not say who applies them.

Clause four sends you to the annex: disposal is carried out in accordance with the method set out in Annex 3. And Annex 3 names re-injection, with two routes. The first is re-injection into depleted wells: the solid NORM is mixed with cement and discharged into abandoned wells, where it sits between two plugs inside the well. The second is injection into wells by hydraulic fracturing. Sludge, the soft solid out of separators and tanks, and scale, the hard crust inside pipes and production equipment, are first mixed with mud or cement in special mixing facilities, then injected, with a large quantity of water, into the oil reservoir or, by hydraulic fracturing, into a basin geologically and mechanically separated from groundwater sources used for drinking, so that they all move together in the reservoir.

What article 12 and Annex 3 do not say

They do not give a concentration above which disposal is required or below which it is not. That question belongs to the exemption route: article 5 exempts radioactive waste arising from practices subject to licensing and registration from the application of the provisions of the regulations in force where its activity is below the Annex 1 levels, and if it is above, that article treats the material as radioactive contaminants, to be collected, transported, stored and disposed of. Note that the article says contaminants, not waste.

They set no depth, no distance from a water source expressed in metres, no cement mix, no injection pressure and no volume limit. The second annex method gives a geological condition in words, a basin separated geologically and mechanically from drinking groundwater sources, and that is the whole of the separation requirement the annex sets. They set no monitoring duty after injection, no closure record and no retention period for it. And in what we have seen of this decision there is no penalty word and no deadline attached to this article.

And a boundary worth keeping. Storage is not disposal. The storage article describes keeping the material temporarily pending final disposal, with its own store requirements, its register and its dose figures. Disposal is the end of the chain. Storage remains storage and not disposal, however many years it lasts. Whether a given store meets the requirements is measured against all eight clauses of article 10 — siting, build with its barrier, floor, ventilation, kit, register, the two dose ceilings and the monitoring — not against any one of them alone.

Article 12 clause by clause

The table sets each clause against what it obliges and what it leaves open, so the gaps are as visible as the duties.

What to do, in order

Disposal is the one stage you cannot undo, so the order matters more here than anywhere else in these rules. Settle the route first: Annex 3 names re-injection, and both of its routes need a well and a reservoir, which means the decision is taken with your subsurface people and not only with the environment team. If no well is available to you, the annex leaves you no route, and it is better to know that early.

Then screen the site against the four criteria and write the screen down, because the clause names the criteria and not the evidence, so your file is the evidence. Then condition the waste, and record what the conditioning did in the terms of the definition: what form it changed to, what volume it came down to, what it is contained in. Last, keep the storage chain intact until the day of disposal, since the store register and the monitoring rounds continue to apply right up to the end.

Questions we are actually asked

Technical note

Conditioning changes the hazard profile as well as the volume, and the direction is not always the one people expect. Mixing solids with cement, which is what the first annex route describes, reduces the chance of material becoming airborne and increases the mass and volume of the package, a package being the radioactive material together with its packaging, prepared for transport. The dose rate at the package surface is not settled by any single rule: the total activity is unchanged, while the added material both shields and moves the surface away from the source, so the direction depends on geometry and emitter and is established by measurement. Less inhalation risk and a heavier drum, and the reading is taken after conditioning rather than assumed. That is the nature of the operation, not a matter of wording.

Two cautions on the mixing stage itself. It is a dry-handling operation at the point where solids go into the mixer, so it is the step at which dust is raised, and the collection article's logic about wetting dry contaminated material to prevent airborne radioactive material is worth learning from here; the decision does not refer the mixing stage to that article, and we do not claim it does. And the mixer, the lines and the pumps come off the job contaminated. Treating them on the logic of the decontamination article, with its priority method and its filters, is something we take as guidance and do not treat as binding; the decision does not name mixing plant in that article.

And a word on who does this work. The screening, the conditioning records, the surveys and the injection itself are carried out by the operator's people and its contractors. This is what we train and advise on; it is not work we carry out.

How DITEC helps, and where its work stops

The question we get on this article is almost always the same one: where does it finally go. The useful answer starts from Annex 3 and from whether a well and a reservoir are available to you at all. We train on reading article 12 with its annex, and advise on the site screen and the conditioning record.

ALDuha Institute for Training and Environmental Consulting (DITEC) works in training and consulting. The Institute does not run a laboratory analysis service, does not calibrate instruments, and does not test equipment. Field survey work is arranged through specialist partners.

Our training is licensed. Nothing here is an undertaking that a licence will be issued, and nothing here promises how long any application takes. The decision rests with the Ministry of Environment and Climate Change, Radiation Protection Department.

Reference: DITEC Experts and the Radiation Protection team. This page is an introductory explanation of a published decision and is not a legal opinion.