23
TUNISIA
Serinus Tunisia maintained a strong HSE track record through 2023, with a zero-frequency rate (per one million
man hours worked) for Total Recordable Injuries across all sites (2022 – zero for Serinus Tunisia employees).
There were no environmental incidents at Sabria and two minor incidents at Chouech Es Saida which were
addressed and repaired. Serinus Tunisia has maintained full compliance with all of its regulatory and environmental
obligations.
Environmental monitoring has been undertaken across all of our Tunisian fields since 2014 in compliance with legal
requirements and the Group’s responsibilities to the local environment. The annual environmental report for 2023
was submitted to the Agence Nationale de Protection de l’Environnement (“ANPE”) in January 2024.
During 2023, the annual environmental monitoring was undertaken by Le Centre Mediterraneen d’Analyses (“CMA”)
at the Sabria and Chouech Es Saida fields, assessing: air emissions from stacks at both fields; air quality monitoring;
groundwater monitoring; produced water; fresh water; soil sampling and noise pollution. The environmental
monitoring programme for remote locations is reviewed by local management and implemented at all sites.
Stack air emission analysis and air quality monitoring was conducted at Sabria and Oum Chiah in September 2023.
Analysis of the results demonstrated that the Group was in compliance with approved thresholds of groundwater
and soil contaminants and required solid waste management. The Group’s own review of air emissions showed
compliance in all areas, in accordance with the air quality limits set by Decree No. 2018-447 of 18 May 2018 and
Decree No.2010-2519 of 28 September 2010, except for carbon monoxide (“CO”) emissions from older fixed
equipment. The Group has investigated mitigation measures and a short and medium-term action plan with an
enhanced preventative maintenance programme has been implemented to address this, including the refurbishment
and overhaul of affected equipment. Ground water monitoring is conducted on a yearly basis from existing water
wells drilled at Sabria. No evidence of pollution has been reported. Five piezometer wells were drilled at Sabria to
monitor the ground water table in 2014 which continue to be monitored.
The water disposal project manages produced water production at Sabria. This formation water has high salinity
(360 grams/litre) with traces of heavy metals. Until 2015, disposal at Sabria was conducted by discharge into lined
surface pits for natural evaporation of fluids. The low efficiency of natural evaporation together with the ongoing
need to construct additional lined pits led to the introduction of automated fracturing evaporator technology in 2015
and which has enabled the acceleration of evaporation of produced water through an automated and a more efficient
process. At Sabria, 37,581m
3
of produced water was disposed of in 2023 (2022 – 49,129m
3
) and at Chouech Es
Saida 196,770m
3
of produced water was evaporated from lined surface pits in 2023 (2022 – 225,283m
3
). The
Group is investigating alternative environmentally-responsible produced water disposal solutions.
A review of environmental management at the Sabria fields was conducted by First North African Consultancy for
the Environment (“FNAC” www.fnac-environment.com), an engineering consultancy, in September 2020. This was
designed to review compliance at Sabria with Tunisian environmental regulations and analyse underground water
and soil pollution in proximity to the water disposal project. The scope of this work included: the recovery, analysis
and assessment of environmental and technical documents and reports related to the evaporation ponds; the
analysis of all previous waste pit treatment operations and related reports; analysis of existing red register
(hazardous waste) and blue register (domestic waste); coring and sampling investigations of the potential impacted
areas (soil and underground water) within the Sabria field; water sampling and laboratory analysis from existing
piezometers and production water discharge; and the performance of an environmental monitoring program of the
potential impacted areas within Sabria field. The program was conducted in conjunction with representatives of
ANPE and the environmental reports were submitted to ANPE. Results from the assessment showed below
threshold levels of potential pollutants set under Tunisian regulations and equivalency with both groundwater and
soil control samples. These demonstrated the efficacy of the water disposal project and the process of produced
water storage in evaporation pits, with no evidence of leakage or overflow from the pits into the soil or groundwater.
Subsequent to this review, recommendations from the report have been, and continue to be, implemented. The
Group began air emissions monitoring at Sabria and Chouech in August 2015 and continues to do so.
Waste management procedures have been implemented in all locations in Tunisia and monitor a comprehensive
range of waste products including industrial waste (dry cell batteries, lead acid batteries, empty gas cylinders, oil
filters, used oil, contaminated waste, used fluorescent lighting), resource waste (diesel consumption), hazardous
waste (sewage, medical waste), domestic waste (food waste, plastic bottles, cooking oil, paper) and office waste
(plastic bottles, paper, printer cartridges, batteries). For example, 1,164 kg of paper and plastic bottles were
recycled in the Tunis office in 2022, which decreased to 784 kg of paper and plastic bottles being recycled in 2023,
as a result of training and greater awareness of wastage. Electricity consumption at the Tunis office in 2023 was
110,337 kWh higher than 2022 (93,920 kWh) as a result of the temporary contractors presence that have been
hired for both Sabria workovers and the geological study of Sabria. At Sabria electricity consumption decreased
12% to 601,259kWh (2022 – 679,902kWh). Chouech is not connected to the electricity grid and power at Chouech
is provided by on site gas generators. Fresh water consumption in 2023 at Sabria was 15,820m
3
(2022 – 16,290m
3
)
and at Chouech, 26,498m
3
(2022 – 41,440m
3
). Diesel consumption across all operational locations was 150m
3
a
2% decrease over 2022 (153m
3
) but remains a significant reduction from 2019 (305m
3
) reinforced by a combination
of greater awareness of wastage, training, optimisation and more efficient transport management.