Discharge, Disposal and Storage of Radioactive Waste in Qatar
October 4, 2026
12 min read
DITEC Experts, Radiation Protection Team, ALDuha Institute for Training and Environmental Consulting
The four articles about where the material actually goes
Every article in this Part up to here has been about duties, licences, people and classes. These four are about destinations, and between them they describe the only three places radioactive waste can end up: released into the environment within authorised limits, sent to a disposal facility, or held in a store. Article 92 sits in the middle of them because segregation is what makes any of the three possible.
The order in the Regulation is the order of preference in practice, and it is worth naming because facilities often reach for the wrong one first. Discharge where the material qualifies and the limits allow. Disposal where it does not. Storage is neither of those - it is the holding state in between, and Article 1 defines it as placing waste in a suitable facility with isolation, environmental protection and monitoring, with the intention of recovering it later for clearance, treatment, conditioning or disposal. A store is not a destination. A store full of waste with no decided destination is the finding the Institute meets most often in this Part.
Article 90: discharge, and the hazard that survives the clearance
Article 90 is headed the discharge of radioactive material to the environment and it is structured as a prohibition with conditions. The licensee must work so that radionuclides are not released to the environment, except in accordance with the following controls: that the discharge limits are within the limits authorised to him by the licence granted to him by the Council, and that the discharge takes place within the conditions determined by the Committee; and that the radioactivity of the liquid and gaseous waste being discharged is within the limits set by the Committee.
Two sources of limit are stacked there and both bind: the limits in your own licence, and the limits set by the Committee. A facility whose licence is silent on discharge has not thereby been given a free hand - it has been given a reason to ask, because the default in the opening words is that radionuclides are not released.
The article then provides a route for exceeding those levels, and it is a route through the Ministry rather than around it. If the licensee wishes to release gaseous, liquid or solid radioactive waste to the environment with a radioactivity exceeding the levels determined by the Committee, he must submit a written application to the Council to be put before the Committee, which has the right to refuse or accept it. Note that the application route covers solid waste too, although the second control above speaks only of liquid and gaseous.
Four further duties follow, and they are the ones that turn an authorised limit into something that can be demonstrated. To keep the discharge and release of radionuclides at the lowest level achievable within economic and technical limitations, below the authorised limits. To monitor and record the discharge and release in sufficient detail and accuracy to show compliance with the authorised discharge limits and with the permitted exposure of population groups. To submit a discharge report to the Council within the periods the Council determines. And to report to the Council immediately on any discharge or release exceeding the authorised limits.
Item 1 is the article's own optimisation rule and the phrase below the authorised limits does real work: being inside the limit is the ceiling, not the target. Item 2 names the two things the monitoring has to be able to show. The first is compliance with the limits, and sufficient detail and accuracy is a technical requirement rather than an adjective: the method has to be able to see below the level being demonstrated, so a measurement whose detection limit sits above the authorised discharge limit demonstrates nothing at all, and the demonstration needs both the activity concentration in the effluent and the total activity discharged over the reporting period, since a limit may be written in either quantity. The second is the permitted exposure of population groups, which the Institute reads as the critical group - the group whose location, habits and diet make it the most exposed through the pathway that actually controls the dose, and therefore the group the monitoring has to be designed around; the public exposure chapter, Articles 56 and 58, is built on the same idea. Naming that group and that pathway is what turns a stack or an outfall reading into a demonstration. And item 4's immediately is the shortest deadline in the Part; Article 96 then sets a written report within twenty-four hours for release above the clearance levels or discharge above the Committee's limits - a related but differently drawn trigger.
The closing paragraph of the article is the one that is quoted least and matters most in a hospital or a laboratory. When radioactivity is released within the discharge levels the Committee permits, or when radioactive waste is discharged under an authorisation, the non-radiological hazards of the waste being discharged must be taken into account, and any other regulatory requirements concerned with those hazards must be complied with. In other words a radiological clearance is not a general clearance. Solvent is still solvent, a cytotoxic agent is still cytotoxic, and the drainage and chemical waste rules apply on their own terms.
Article 91: the application to dispose
Article 91 is headed the disposal of radioactive waste and it is one sentence. When the radioactive waste is not suitable for discharge or release to the environment, or for clearance within a reasonable period of time, everyone who has such waste must submit an application to the Council to dispose of it, while assuring that the criteria set by the Council and the Committee for accepting radioactive waste in any repository or in any national waste management body are met.
Three things in it are worth drawing out. The trigger is a negative finding - not suitable for discharge, and not reaching clearance within a reasonable period. So this article is reached by elimination, and the facility has to have actually performed the elimination: asked whether the stream can be discharged under Article 90, and whether it will clear under Article 81, before concluding that it cannot.
The obligation is on everyone who has such waste. That is wider than the licensee, and it is deliberate: holding waste you cannot discharge creates a duty to apply whether or not you were the one who generated it. And the application is accompanied by a substantive condition, not merely a form - assuring that the acceptance criteria set by the Ministry and the Committee are met. The acceptance criteria are what Article 1's definitions of conditioning, waste form, waste container and waste package exist to serve: material is not accepted loose, it is accepted as a package that meets stated criteria.
Where the waste goes is referred to rather than specified: any repository or any national waste management body. Article 1 defines a repository as a facility in which waste is placed for disposal and from which it will not be recovered in future. The practical reading for a licensee is that the destination, its acceptance criteria and the route to it are matters to establish with the Ministry before a stream accumulates, because the alternative is a store filling up while the question is unanswered - and Articles 93 and 95 then start applying to a store that was never designed to be a destination.
Article 92: segregation at the place of generation
Article 92 is headed the segregation of radioactive waste into groups, its collection and its characterisation. The licensee must assure the segregation of radioactive waste into groups at the place of its generation, in accordance with what the Committee determines, and the waste is segregated into groups on the basis of the categories, which help in using the treatment options available.
At the place of its generation is the operative phrase and it rules out the arrangement most facilities drift into: one bin at the bench, sorted later by whoever empties it. The reason the Regulation puts segregation at the bench is that information is destroyed by mixing. Once two streams are in one container, nobody can say which nuclide is in which item, and the classification Article 87 requires as soon as the waste is generated has become unrecoverable - along with the possibility of decay storage, since class 2 needs short-lived nuclides and nothing else.
The basis of segregation is also stated, and it is forward-looking rather than tidy: on the basis of the categories, which help in using the treatment options available. So the groups are not chosen for neatness; they are chosen so that each group has somewhere to go. A facility that segregates into categories for which no treatment or disposal route exists has done the filing without doing the thinking.
The second paragraph adds the two mechanical requirements. After the radioactive waste is segregated into groups, each type of waste should be kept in a separate container, and the containers are labelled according to the conditions set by the Committee. A separate container per type, and labels on the Committee's conditions - so the labelling scheme is not a local design choice either, and a facility that has invented its own labels should check them against the conditions in force.
Article 93: what a waste store has to be
Article 93 is headed the storage of waste, and it is the longest and most concrete article in the Part. It opens as a prohibition. The storage of radioactive waste is forbidden except in the manner that achieves the protection of human health and the environment, and in particular this waste must not be stored near corrosive, explosive or flammable materials.
The named incompatibilities are worth taking literally, because the room that ends up holding radioactive waste in a small facility is very often the same general store that holds the solvents and the gas cylinders. Corrosive, explosive or flammable - all three are common in exactly the laboratories that generate this waste, and the prohibition is about proximity rather than contact.
The second paragraph adds three structural requirements. The boundaries of the facilities or areas designated for storing radioactive waste must be clearly shown, with control over the points of approach to them, and the storage areas for untreated waste should be separated from the waste that has undergone conditioning. The separation of untreated from conditioned waste is the one most often absent, and it is not cosmetic: a conditioned package has a verified form and an identification number under Article 94, and mixing it back among untreated material destroys the distinction the records depend on.
Then comes the list of twelve features the storage facilities or areas must have. They are reproduced in the table below as the article states them. Several deserve a word here. Item 1 asks for sufficient capacity to take the waste generated before discharge, treatment and transport - that is, the store must be sized against the facility's actual generation rate and the actual interval between collections, not against the space that happened to be free. Item 9 requires a performance log identifying the list of containers, the date of their entry, the type of radioactive waste and, in the instrument's own words, its radiological regime, which in practice means the nuclides and their activity; and it adds that the log should be kept outside the storage place, near the place or area of storage. Outside, and near, for three reasons worth saying out loud: the record has to survive a fire or a spill inside the store, which is the event it will be needed for; anyone - a responder, an inspector, the officer - has to be able to read what is inside before opening the door rather than after; and a log kept inside has to be carried in and out, which makes the paperwork a contamination pathway of its own.
Item 4's adequate ventilation needs one more word than it looks like it needs. Ventilation in a waste store is there to carry volatile and gaseous activity away from whoever opens the door - iodine-131 from a decay store, radon ingrowth from a radium source, gas from radiolysis in aqueous or organic waste - and a recirculating air-conditioning unit does the opposite, spreading contamination through the building. The arrangement the article contemplates exhausts to outside, with the store held at a lower pressure than the areas around it; and what leaves that exhaust is a release to the environment, so Article 90 and the air sampling in item 5 apply to it. Item 7 names volatile, pathogenic, putrescible and chemically active materials, and it carries a warning the rest of this Part does not state: those hazards do not decay. A radioactive animal carcass or culture put into decay storage for ten half-lives will be an infection and pressure problem long before it is a radiological non-problem, and decomposition can breach the very container that was the containment. Where a stream is both radioactive and putrescible or pathogenic, the holding time is set by the biological hazard - in practice freezing, or inactivation before storage, or a short retention agreed with the Ministry - and not by radiological decay alone. Item 8 asks that the boundaries be easy to designate as radiologically controlled areas, and designation is not a sign on a door: it brings the controlled-area regime with it - access control, local rules for entry, monitoring on the way out, and individual monitoring for those who work in there - so the store should be laid out so the controlled area can be drawn tightly around the waste rather than around a whole room that is also used for other things. Item 11 is protection against intrusion, and this series keeps a firm boundary there. The regulatory duty is stated: a store has to be protected against intrusion, and Article 95 separately requires the licensee to assure that all means are taken to prevent unauthorised persons from entering the areas where radioactive waste is stored, collected, treated or kept. What the arrangement consists of is a matter for the facility and the Ministry, and this explanation does not describe it.
One closing observation about this article as a whole. Read the twelve features together and they describe a purpose-built room, not a cupboard: non-combustible walls and floors that are easy to decontaminate, an impermeable floor covering with containment edges and gentle slopes to a central liquid collection area, adequate ventilation, air sampling and radiological alarm, fire detection, partitions between waste types, and movable shielding as needed. Few small facilities have all twelve. The practical recommendation is to use the article as a gap list to put in front of the Ministry with a plan, rather than treat it as a standard to be quietly failed.
The twelve features of a waste store under Article 93
| Item | What the article requires |
|---|---|
| 1 | Sufficient capacity to take the waste generated before discharge, treatment and transport |
| 2 | A simple structure of non-combustible walls and floors that are easy to decontaminate |
| 3 | An impermeable floor covering with containment edges and gentle slopes to a central liquid collection area |
| 4 | Adequate ventilation |
| 5 | The possibility of collecting air samples, and radiological alarm |
| 6 | Fire detection and fire protection means available |
| 7 | Partitions to separate the different types of radioactive waste, to make safe storage easier for materials of special hazard, volatile, pathogenic, putrescible and chemically active materials |
| 8 | Boundaries easy to designate as radiologically controlled areas |
| 9 | A performance log identifying the containers, the date of entry, the type of radioactive waste and its radiological regime - the nuclides and activity - kept outside the storage place, near it |
| 10 | Protection of the waste from the surrounding environment, including temperatures |
| 11 | Protection against intrusion - the duty is stated here; the arrangement is not published |
| 12 | Movable radiation shielding used as needed |
Questions these articles get asked
Our licence says nothing about discharge limits. Does that mean we may discharge freely?
No - it means the opposite. Article 90 opens with the duty to work so that radionuclides are not released to the environment, and then permits discharge only within the limits authorised by the licence granted by the Council and within the conditions and limits set by the Committee. A licence that is silent has not authorised a limit, so there is nothing to discharge within. The step to take is to ask the Ministry for the discharge limits applicable to your practice, in writing, and to keep them with the waste records alongside the Committee's clearance levels.
Our radioactive waste has decayed below clearance. Can it go down the sink or into the ordinary bin?
The radiological question and the general question are two different questions, and this is exactly what the last paragraph of Article 90 is about. Radiologically, Article 81 exempts waste whose content of radionuclides is below the clearance levels determined by the Committee, and that has to be demonstrated by measurement rather than inferred from a date. But the closing paragraph of Article 90 requires the non-radiological hazards of the waste being discharged to be taken into account and any other regulatory requirements concerned with those hazards to be complied with. So a cleared vial that is also cytotoxic, or a cleared liquid that is also a solvent, goes down the route its chemical or clinical nature requires. Clearance ends the radiological control; it ends nothing else.
Can we sort our waste later at the store instead of at the bench?
Article 92 requires segregation into groups at the place of its generation, so no. The reason is practical rather than formal: mixing destroys the information that later decisions depend on. Article 87 requires the classification to be made as soon as the waste is generated, and class 2 decay waste requires short-lived nuclides and nothing else - a condition that cannot be verified about a container that was filled from several benches. Article 92 also requires each type to be kept in a separate container, with the containers labelled according to the conditions set by the Committee, which is a second reason the sorting cannot be deferred.
Our store does not have all twelve features in Article 93. What should we do?
Treat the twelve as a gap list and take it to the Ministry with a plan, rather than leave the position undeclared. Three of them are worth doing first in most small facilities because they cost little and matter most: separating untreated waste from conditioned waste, which the second paragraph requires; moving the store away from corrosive, explosive and flammable materials, which the opening prohibition requires in terms; and setting up the performance log in item 9 and keeping it outside the storage place but near it. Two of the twelve cannot sit on the list while the store keeps filling, though, because they are what stops a small problem becoming an event: the ventilation in item 4 wherever anything volatile is held, and the fire detection and protection in item 6, which sits next to the opening prohibition on corrosive, explosive and flammable materials. Where a feature is missing, the interim measure is to reduce what the store is asked to hold - less activity, less volatile material, shorter retention, and movable shielding under item 12 where the dose rate at the door calls for it - and to write that limitation into the plan you take to the Ministry. A declared gap is not an authorisation to go on storing as before. Note also that the prohibition at the head of the article is the operative rule - storage is forbidden except in the manner that achieves the protection of human health and the environment - so the twelve features are how that manner is evidenced, not a separate checklist.
We have waste we cannot discharge and cannot clear. Where does it go?
That is precisely the trigger in Article 91, and the step it requires is an application to the Council to dispose of the waste, assuring that the acceptance criteria set by the Council and the Committee for any repository or national waste management body are met. Two points of practice follow. First, the application is yours to make and the duty rests on everyone who has such waste, so holding it is not a neutral position. Second, the acceptance criteria usually govern the package rather than the material - Article 1's definitions of conditioning, waste form, waste container and waste package are built around that - so ask for the criteria early, because they may determine how the stream has to be conditioned before it is accepted at all.
How the Institute can help
The gap we find most often in these four articles is not a breach of the storage standard - it is a store with no decided destination. Storage is defined in the Regulation as holding waste with the intention of recovering it later for clearance, treatment, conditioning or disposal, so a store without an answer to which of those four is coming next is being used for something the instrument does not contemplate. The second most common is a licence that is silent on discharge limits in a facility that discharges.
Radiation Protection Officer training covering the waste chapter and storage, advisory support in requesting and recording the discharge limits and clearance levels your practice needs, help in designing a segregation and labelling scheme that works at the point of generation as Article 92 requires and in setting up the performance log of item 9 of Article 93, and a gap review - documentary, plus a walk-through by eye - of your store against the twelve features and of your waste records against Articles 90 to 93 one by one, written so that it can be put in front of the Ministry with a plan. No part of that review involves measurement: dose-rate and contamination surveys and monitoring of releases come from specialist partners, and instrument calibration and engineering work on the store are outside what the Institute provides.
Scope of what the Institute does: training and consulting. Field radiation surveys are carried out through specialist partners working in the field. The Institute does not carry out laboratory analysis, instrument calibration or equipment testing.
A note on the authority named in the text. The Regulation says the Council, meaning the Supreme Council for the Environment and Natural Reserves. That body no longer exists. Competence today sits with the Ministry of Environment and Climate Change, and the unit concerned is named in the organisational decisions as the Radiation Protection Department. The word Council is kept inside the quotations because it is what the instrument says; everywhere else, read it as the Ministry.
This explanation is published for awareness by the radiation protection team at ALDuha Institute for Training and Environmental Consulting. The English text is an explanation, not a certified translation: the Arabic text published in the Official Gazette governs in case of any difference, and the official Arabic wording of every article discussed here is quoted in full on the Arabic version of this article. This explanation is introductory. It is not a legal opinion, it does not replace the conditions of your own licence, and it does not replace review by the regulator. Last updated 4 October 2026.