Statewide Rule 56 explained: identifiable vs. nonidentifiable hydrocarbons
Statewide Rule 56 (16 Texas Administrative Code §3.56), “Scrubber Oil and Skim Hydrocarbons,” governs how recovered liquid hydrocarbons are accounted for and whether they are identifiable or nonidentifiable. The nonidentifiable skim hydrocarbons recovered during produced water disposal are the volumes reported to the Commission on Form P-18.
What Rule 56 covers
Statewide Rule 56 is section 3.56 of the Railroad Commission’s Oil and Gas Division rules, titled “Scrubber Oil and Skim Hydrocarbons.” It sets out how recovered liquid hydrocarbons are accounted for, and it is the framework behind the P-18: it defines what counts as identifiable versus nonidentifiable, and which volumes have to be reported to the Commission.
Scrubber oil vs. skim hydrocarbons
The rule distinguishes two recovered streams. Scrubber oil is the liquid hydrocarbons that accumulate in lines transporting casinghead gas and are captured at the inlet to a gas processing plant. Skim hydrocarbons are the oil and condensate that accumulate during produced water disposal operations, which is what most saltwater disposal operators are reporting.
Identifiable vs. nonidentifiable
Liquid hydrocarbons are identifiable when the origin of the volume received at the gas plant or produced water disposal facility can be clearly identified. When the origin cannot be traced, the volume is nonidentifiable. Under Rule 56, all unidentifiable liquid hydrocarbons recovered by a single or multiple operator produced water disposal system are reported on Form P-18 for each reporting period.
What this means for your filing
Identifiable volumes returned to the producing property during the same reporting period in which they are received are not reported to the Commission, but the facility operator must notify the appropriate Commission district office by telephone before those volumes are returned. Everything nonidentifiable flows onto the P-18. In practice, this is why source documentation matters: tracing a barrel to a producing property is what keeps it identifiable, and keeps it yours.
Frequently asked
What is Statewide Rule 56?
Statewide Rule 56 is 16 Texas Administrative Code §3.56, “Scrubber Oil and Skim Hydrocarbons.” It governs how recovered liquid hydrocarbons are accounted for and whether they are identifiable or nonidentifiable.
What are skim hydrocarbons?
Under Rule 56, skim hydrocarbons are the oil and condensate that accumulate during produced water disposal operations. They are distinct from scrubber oil, which accumulates in casinghead gas lines and is captured at a gas plant inlet.
What is the difference between identifiable and nonidentifiable hydrocarbons?
Identifiable hydrocarbons are those whose origin can be clearly identified when received at the facility. Nonidentifiable hydrocarbons cannot be traced to a source, and all nonidentifiable volumes recovered by a produced water disposal system are reported on the P-18.
What happens to nonidentifiable hydrocarbons?
They are reported to the Commission on Form P-18 each reporting period. If your fluid balance does not reconcile and volumes cannot be traced to a producing source, they remain nonidentifiable and can be exposed to seizure.
Official sources
Emergent Environmental is not affiliated with the Railroad Commission of Texas. This guide is informational; the official P-18 instructions are authoritative.
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