❓ A WA parliamentary question probes the environmental impact of Buru Energy's oil production at the Ungani facility, focusing on wastewater disposal, chemical usage, and regulatory oversight. The response clarifies DWER's role and refers some queries to the Minister for Mines and Petroleum.
AnsweredQoN 35Legislative Council
QuestionView source ↗
I refer to the latest Environment Plan (EP) for
the recommencement of oil production at the Ungani Oil Production Facility east
of Broome in the Kimberley (HSE-SUM-072, Revision 1, 02/10/2024) in which the
operator, Buru Energy Ltd, states, “The primary method for disposal of produced
water will be via reinjection into
the Ungani 3 or Ungani West 1 wells”; the EP further states, under the 'Chemical
Disclosure' table, that approximately 1,000 kilolitres (1,000,000 litres) of produced
formation water could be disposed of per day via the produced water disposal
system, and that the produced formation water for disposal down the wells
contains multiple chemicals of varying toxicities, including scale inhibitors, corrosion
inhibitors, biocides, emulsion breakers, oxygen scavengers and demulsifiers: (a) I refer to Department of Water and Environmental Regulation (DWER) responses given to the
‘Estimates and Financial Operations Committee 2023-24 Budget Estimates Questions Prior to Hearings’ where it stated, “DWER authorises the disposal
of formation fluids generated as part of petroleum operations on the premises
to specific disposal points (bores), as this relates to the disposal of waste
generated from a prescribed activity", and I ask: (i) what is the specific authorisation
provided by DWER for the disposal by Buru Energy of formation fluid waste,
including a range of toxic chemicals used in the production of oil, down
reinjection wells at the Ungani Oil Production Facility (prescribed premises); (ii) when does this authorisation expire; and (iii) has Buru Energy complied with all conditions
under that authorisation; (b) what volume of produced formation wastewater
(fluid) has Buru Energy disposed of down each of its licensed waste disposal reinjection
wells, including Ungani Far West 1, at the Ungani Oil Production Facility in
each of the past five years; (c) has DWER conducted any hydrogeological studies
to understand the movement of this contaminated wastewater (fluid) and its
chemical constituents once disposed of by Buru Energy down its Ungani
reinjection wells; (d) if yes to (c), what studies have been done and where are they publicly available; (e) if no to (c), why not; (f) does Buru Energy use the reinjection of produced
formation wastewater (fluid) to force reservoir oil to the surface, a common
oilfield process known as waterflooding; (g) if yes to (f), is this process of enhancing oil
production at Ungani conducted at pressure; (h) if yes to (f) and (g), is DWER concerned that reinjecting contaminated wastewater at pressure may cause changes to local hydrogeological conditions which could result in groundwater contamination; (i) if no to (h), why not; (j) does the produced formation wastewater (fluid) disposed
of by Buru Energy down reinjection wells at Ungani contain BTEX chemicals; (k) is Buru Energy authorised to dispose of BTEX
chemicals down its wastewater (fluid) disposal reinjection wells at Ungani; (l) if yes to (k), through what authorisation and in what amount; (m) has DWER conducted any testing of the produced
formation wastewater (fluid) disposed of down reinjection wells by Buru Energy
at the Ungani Oil Production Facility, prior to disposal; (n) if yes to (m), when was the testing done and what were the results; (o) if no to (m), why not; (p) I refer to question
on notice 205, from 2021, and ask, is it still the case that the
most recent DWER site inspection at the Ungani Oil Production Facility, a DWER
licensed ‘prescribed premises’, was ten years ago on 10 June 2015; (q) if no to (p), when was a more recent inspection conducted by DWER: (i) where can the public access the inspection report; (r) if the most recent inspection was ten years ago
in 2015, as referenced in (p), does DWER have any plans for compliance site inspections at the Ungani prescribed premises; (s) if yes to (r), when; (t) if no to (r), why not; (u) according to page 3 of the Buru Energy Environment
Plan, “All [other] waste types (putrescible, recyclable and industrial)
will be removed from the Ungani Production Facility and disposed offsite by an
approved waste disposal contractor. I ask: (i) what forms and amounts of industrial waste are
produced at the Ungani prescribed premises and disposed of offsite; (ii) are the forms and quantities of industrial waste
for offsite disposal kept by Buru Energy and provided to DWER; (iii) if yes to (ii), can the most recent examples be tabled; (iv) how and where are these industrial wastes
disposed of; (v) do the industrial wastes produced at Ungani and
disposed of offsite contain toxic materials; (vi) if yes to (v), what types of toxic materials and in what amounts; (vii) in addition to the authorisation from DWER to
dispose of contaminated liquid wastes (produced formation water) down reinjection
wells at the Ungani prescribed premises, is the offsite disposal of industrial
waste licenced by DWER; (viii) if yes to (vii), what is the exact form of authorisation
provided to Buru Energy for this offsite disposal of industrial waste, what
conditions apply and when does it expire; (ix) does DWER monitor the final disposal of the
industrial waste disposed of offsite by Buru Energy from its Ungani prescribed premises; (x) if no to (ix), why not; and (xi) what is the final fate of the industrial waste
disposed of offsite by Buru Energy from its Ungani prescribed premises; (v) are there any other waste disposal
authorisations provided by DWER for the Ungani Oil Production Facility prescribed premises; (w) does the Ungani Oil Production Facility prescribed premises emit methane gas and/or volatile organic compounds (VOCs); (x) if yes to one or both in (w), please specify the following: (i) in what amounts annually for each of the past five years; (ii) is the release into the atmosphere of methane and/or VOCs authorised by DWER; (iii) if no to (ii), why not; (iv) is the release of methane and/or VOCs monitored by DWER; (v) if no to (iv), why not; (vi) are there any limits placed by DWER on atmospheric pollution from Buru Energy’s Ungani Oil Production Facility prescribed premises; and (vii) if no to (vi), why not; (y) as a prescribed premises licenced by DWER, is Buru
Energy required to submit annual compliance reports to the Department; (z) if yes to (y), has Buru Energy complied with this requirement; (aa) if yes to (z), where can the public access the annual compliance reports; (bb) if no to (z), why not; (cc) given that under this EP, Buru Energy is
proposing to reopen the Ungani Oil Production Facility and recommence oil exports, after approximately
18 months of suspension, does the Department consider it prudent to carry out a
full audit of the condition of the production facility/prescribed premises in
relation to the laws and regulations the Department is responsible for,
including water management, waste disposal, pollution and contaminated sites,
prior to reopening; (dd) if no (cc), why not; and (ee) given that Buru Energy has stated that it
intends to switch its Ungani oil export trucking route from Wyndham port to
either Broome port or Derby port, what involvement will DWER have in assessing
the risks to the Broome and Derby communities, and the King Sound and Roebuck
Bay marine environments, from oil trucking, loading and shipping?
the recommencement of oil production at the Ungani Oil Production Facility east
of Broome in the Kimberley (HSE-SUM-072, Revision 1, 02/10/2024) in which the
operator, Buru Energy Ltd, states, “The primary method for disposal of produced
water will be via reinjection into
the Ungani 3 or Ungani West 1 wells”; the EP further states, under the 'Chemical
Disclosure' table, that approximately 1,000 kilolitres (1,000,000 litres) of produced
formation water could be disposed of per day via the produced water disposal
system, and that the produced formation water for disposal down the wells
contains multiple chemicals of varying toxicities, including scale inhibitors, corrosion
inhibitors, biocides, emulsion breakers, oxygen scavengers and demulsifiers: (a) I refer to Department of Water and Environmental Regulation (DWER) responses given to the
‘Estimates and Financial Operations Committee 2023-24 Budget Estimates Questions Prior to Hearings’ where it stated, “DWER authorises the disposal
of formation fluids generated as part of petroleum operations on the premises
to specific disposal points (bores), as this relates to the disposal of waste
generated from a prescribed activity", and I ask: (i) what is the specific authorisation
provided by DWER for the disposal by Buru Energy of formation fluid waste,
including a range of toxic chemicals used in the production of oil, down
reinjection wells at the Ungani Oil Production Facility (prescribed premises); (ii) when does this authorisation expire; and (iii) has Buru Energy complied with all conditions
under that authorisation; (b) what volume of produced formation wastewater
(fluid) has Buru Energy disposed of down each of its licensed waste disposal reinjection
wells, including Ungani Far West 1, at the Ungani Oil Production Facility in
each of the past five years; (c) has DWER conducted any hydrogeological studies
to understand the movement of this contaminated wastewater (fluid) and its
chemical constituents once disposed of by Buru Energy down its Ungani
reinjection wells; (d) if yes to (c), what studies have been done and where are they publicly available; (e) if no to (c), why not; (f) does Buru Energy use the reinjection of produced
formation wastewater (fluid) to force reservoir oil to the surface, a common
oilfield process known as waterflooding; (g) if yes to (f), is this process of enhancing oil
production at Ungani conducted at pressure; (h) if yes to (f) and (g), is DWER concerned that reinjecting contaminated wastewater at pressure may cause changes to local hydrogeological conditions which could result in groundwater contamination; (i) if no to (h), why not; (j) does the produced formation wastewater (fluid) disposed
of by Buru Energy down reinjection wells at Ungani contain BTEX chemicals; (k) is Buru Energy authorised to dispose of BTEX
chemicals down its wastewater (fluid) disposal reinjection wells at Ungani; (l) if yes to (k), through what authorisation and in what amount; (m) has DWER conducted any testing of the produced
formation wastewater (fluid) disposed of down reinjection wells by Buru Energy
at the Ungani Oil Production Facility, prior to disposal; (n) if yes to (m), when was the testing done and what were the results; (o) if no to (m), why not; (p) I refer to question
on notice 205, from 2021, and ask, is it still the case that the
most recent DWER site inspection at the Ungani Oil Production Facility, a DWER
licensed ‘prescribed premises’, was ten years ago on 10 June 2015; (q) if no to (p), when was a more recent inspection conducted by DWER: (i) where can the public access the inspection report; (r) if the most recent inspection was ten years ago
in 2015, as referenced in (p), does DWER have any plans for compliance site inspections at the Ungani prescribed premises; (s) if yes to (r), when; (t) if no to (r), why not; (u) according to page 3 of the Buru Energy Environment
Plan, “All [other] waste types (putrescible, recyclable and industrial)
will be removed from the Ungani Production Facility and disposed offsite by an
approved waste disposal contractor. I ask: (i) what forms and amounts of industrial waste are
produced at the Ungani prescribed premises and disposed of offsite; (ii) are the forms and quantities of industrial waste
for offsite disposal kept by Buru Energy and provided to DWER; (iii) if yes to (ii), can the most recent examples be tabled; (iv) how and where are these industrial wastes
disposed of; (v) do the industrial wastes produced at Ungani and
disposed of offsite contain toxic materials; (vi) if yes to (v), what types of toxic materials and in what amounts; (vii) in addition to the authorisation from DWER to
dispose of contaminated liquid wastes (produced formation water) down reinjection
wells at the Ungani prescribed premises, is the offsite disposal of industrial
waste licenced by DWER; (viii) if yes to (vii), what is the exact form of authorisation
provided to Buru Energy for this offsite disposal of industrial waste, what
conditions apply and when does it expire; (ix) does DWER monitor the final disposal of the
industrial waste disposed of offsite by Buru Energy from its Ungani prescribed premises; (x) if no to (ix), why not; and (xi) what is the final fate of the industrial waste
disposed of offsite by Buru Energy from its Ungani prescribed premises; (v) are there any other waste disposal
authorisations provided by DWER for the Ungani Oil Production Facility prescribed premises; (w) does the Ungani Oil Production Facility prescribed premises emit methane gas and/or volatile organic compounds (VOCs); (x) if yes to one or both in (w), please specify the following: (i) in what amounts annually for each of the past five years; (ii) is the release into the atmosphere of methane and/or VOCs authorised by DWER; (iii) if no to (ii), why not; (iv) is the release of methane and/or VOCs monitored by DWER; (v) if no to (iv), why not; (vi) are there any limits placed by DWER on atmospheric pollution from Buru Energy’s Ungani Oil Production Facility prescribed premises; and (vii) if no to (vi), why not; (y) as a prescribed premises licenced by DWER, is Buru
Energy required to submit annual compliance reports to the Department; (z) if yes to (y), has Buru Energy complied with this requirement; (aa) if yes to (z), where can the public access the annual compliance reports; (bb) if no to (z), why not; (cc) given that under this EP, Buru Energy is
proposing to reopen the Ungani Oil Production Facility and recommence oil exports, after approximately
18 months of suspension, does the Department consider it prudent to carry out a
full audit of the condition of the production facility/prescribed premises in
relation to the laws and regulations the Department is responsible for,
including water management, waste disposal, pollution and contaminated sites,
prior to reopening; (dd) if no (cc), why not; and (ee) given that Buru Energy has stated that it
intends to switch its Ungani oil export trucking route from Wyndham port to
either Broome port or Derby port, what involvement will DWER have in assessing
the risks to the Broome and Derby communities, and the King Sound and Roebuck
Bay marine environments, from oil trucking, loading and shipping?
AnswerView source ↗
Answered
20 May 2025
Responded by
Minister for the Environment
Response time
6 days
(a)
(i) Condition 6 of Licence L8777/2013/1 under Part V, Division 3 of the Environmental Protection Act 1986 authorises produced formation water (PFW) to be discharged to reinjection wells Ungani West 1, Ungani 3 and Ungani 4. The Department of Energy, Mines, Industry Regulation and Safety (DEMIRS) regulates the transport and disposal of PFW via the flowlines and reinjection wells through approved Environment Plans (EP) in accordance with the Petroleum and Geothermal Energy Resources (Environment) Regulations 2012 and Petroleum Pipelines (Environment) Regulations 2012 . The conditions of Licence L8777/2013/1 are limited to authorising the discharge of PFW to specified wells only to avoid regulatory duplication with DEMIRS.
(ii) The licence expires on 17 November 2034.
(iii) Yes. As part of an audit in 2024, Buru Energy was assessed as compliant with the authorisation.
(b) It is recommended that queries on the regulation of PFW disposal are directed to the Minister for Mines and Petroleum.
(c) No. The produced formation wastewater is disposed into a depleted petroleum reservoir that is located at much greater depth compared to groundwater aquifers, which are geologically isolated from each other and do not interact. Further queries on this matter should be directed to the Minister for Mines and Petroleum.
(d – o) Not applicable.
(p) No.
(q) 13 June 2024.
(i) Inspection reports are not publicly available. Inspection reports may be requested via a Freedom of Information request.
(r - t) Not applicable.
(u)
(i) The EP is a requirement under the Petroleum and Geothermal Energy Resources (Environment) Regulations 2012 and Petroleum Pipelines (Environment) Regulations 2012 that are administered by DEMIRS. Queries on Buru Energy’s EP should be referred to the Minister for Mines and Petroleum.
(ii) – (viii) Refer to answer in (u)(i).
(ix) No.
(x) The transport of any industrial waste is regulated under the Environmental Protection (Controlled Waste) Regulations 2004 , where a waste holder is required to engage an appropriately DWER licensed controlled waste carrier to transport the controlled waste to a waste facility that can lawfully accept it for treatment and/or disposal.
(xi) Controlled waste tracking information regarding the collection, transport and unloading of controlled wastes for treatment is the property of individual controlled waste carriers, considered commercial-in-confidence and therefore not publicly available. DWER does perform checks to ensure that tracked waste is taken to appropriate disposal facilities.
(v) No.
(w) Yes.
(x)
(i) DWER does not have this information as the licence holder is not required to report annual VOC emissions under the Environmental Protection Act 1986 .
(ii)-(vii) DWER has assessed the risk of impacts associated with the venting of VOC’s and determined that the risks to public health and environment are negligible and conditions on the licence are not required. This assessment took into account that the nearest residence is approximately 30km east and air dispersion modelling indicates that any reduction in air quality will be restricted to the immediate vicinity (approx. 2m) of the tank vents.
(y) Yes.
(z) Yes.
(aa) Buru Energy Ungani Facility Annual Audit Compliance Reports submitted in accordance with licence requirements for the periods 2019-2020, 2020-21, 2021-22, 2022-23 and 2023-24 are published on DWER’s website available at www.der.wa.gov.au/component/k2/itemlist/filter?fitem_all=L8777&moduleId=94&Itemid=175 .
(bb) Not applicable.
(cc) No.
(dd) The Ungani Facility was audited and inspected on 13 June 2024 in relation to its licence L8777/2013/1 as well as general provisions of the Environmental Protection Act 1986 and the Environmental Protection (Controlled Waste) Regulations 2004 . DWER is satisfied that Buru Energy has put appropriate actions in place to address the findings of the audit. Once the site recommences operations, DWER will consider the need for further audits as part of its future inspection program planning.
(ee) The transport of oil on public roads and loading and unloading at port facilities is not subject to regulatory licensing under Part V, Division 3 of the Environmental Protection Act 1986 . Licensing of ‘bulk material loading and unloading’ at port facilities through category 58 and 58A listed in Schedule 1 of the Environmental Protection Regulations 1987 is limited to clinker, coal, ore, ore concentrate, bulk granular materials and salt.
(i) Condition 6 of Licence L8777/2013/1 under Part V, Division 3 of the Environmental Protection Act 1986 authorises produced formation water (PFW) to be discharged to reinjection wells Ungani West 1, Ungani 3 and Ungani 4. The Department of Energy, Mines, Industry Regulation and Safety (DEMIRS) regulates the transport and disposal of PFW via the flowlines and reinjection wells through approved Environment Plans (EP) in accordance with the Petroleum and Geothermal Energy Resources (Environment) Regulations 2012 and Petroleum Pipelines (Environment) Regulations 2012 . The conditions of Licence L8777/2013/1 are limited to authorising the discharge of PFW to specified wells only to avoid regulatory duplication with DEMIRS.
(ii) The licence expires on 17 November 2034.
(iii) Yes. As part of an audit in 2024, Buru Energy was assessed as compliant with the authorisation.
(b) It is recommended that queries on the regulation of PFW disposal are directed to the Minister for Mines and Petroleum.
(c) No. The produced formation wastewater is disposed into a depleted petroleum reservoir that is located at much greater depth compared to groundwater aquifers, which are geologically isolated from each other and do not interact. Further queries on this matter should be directed to the Minister for Mines and Petroleum.
(d – o) Not applicable.
(p) No.
(q) 13 June 2024.
(i) Inspection reports are not publicly available. Inspection reports may be requested via a Freedom of Information request.
(r - t) Not applicable.
(u)
(i) The EP is a requirement under the Petroleum and Geothermal Energy Resources (Environment) Regulations 2012 and Petroleum Pipelines (Environment) Regulations 2012 that are administered by DEMIRS. Queries on Buru Energy’s EP should be referred to the Minister for Mines and Petroleum.
(ii) – (viii) Refer to answer in (u)(i).
(ix) No.
(x) The transport of any industrial waste is regulated under the Environmental Protection (Controlled Waste) Regulations 2004 , where a waste holder is required to engage an appropriately DWER licensed controlled waste carrier to transport the controlled waste to a waste facility that can lawfully accept it for treatment and/or disposal.
(xi) Controlled waste tracking information regarding the collection, transport and unloading of controlled wastes for treatment is the property of individual controlled waste carriers, considered commercial-in-confidence and therefore not publicly available. DWER does perform checks to ensure that tracked waste is taken to appropriate disposal facilities.
(v) No.
(w) Yes.
(x)
(i) DWER does not have this information as the licence holder is not required to report annual VOC emissions under the Environmental Protection Act 1986 .
(ii)-(vii) DWER has assessed the risk of impacts associated with the venting of VOC’s and determined that the risks to public health and environment are negligible and conditions on the licence are not required. This assessment took into account that the nearest residence is approximately 30km east and air dispersion modelling indicates that any reduction in air quality will be restricted to the immediate vicinity (approx. 2m) of the tank vents.
(y) Yes.
(z) Yes.
(aa) Buru Energy Ungani Facility Annual Audit Compliance Reports submitted in accordance with licence requirements for the periods 2019-2020, 2020-21, 2021-22, 2022-23 and 2023-24 are published on DWER’s website available at www.der.wa.gov.au/component/k2/itemlist/filter?fitem_all=L8777&moduleId=94&Itemid=175 .
(bb) Not applicable.
(cc) No.
(dd) The Ungani Facility was audited and inspected on 13 June 2024 in relation to its licence L8777/2013/1 as well as general provisions of the Environmental Protection Act 1986 and the Environmental Protection (Controlled Waste) Regulations 2004 . DWER is satisfied that Buru Energy has put appropriate actions in place to address the findings of the audit. Once the site recommences operations, DWER will consider the need for further audits as part of its future inspection program planning.
(ee) The transport of oil on public roads and loading and unloading at port facilities is not subject to regulatory licensing under Part V, Division 3 of the Environmental Protection Act 1986 . Licensing of ‘bulk material loading and unloading’ at port facilities through category 58 and 58A listed in Schedule 1 of the Environmental Protection Regulations 1987 is limited to clinker, coal, ore, ore concentrate, bulk granular materials and salt.
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