Who has to file a P-18? SWD and water-gathering operator requirements
You must file a P-18 if you operate a facility, typically a saltwater disposal or water-gathering system, from which skim liquid hydrocarbons (oil or condensate) are recovered and then sold or otherwise disposed. The nonidentifiable hydrocarbons recovered during produced water disposal are reported to the Commission monthly on Form P-18.
The basic test
The P-18 is filed by operators of facilities from which skim liquid hydrocarbons, oil or condensate, are sold or otherwise disposed of by injection or other approved methods. The simple version: if your facility skims hydrocarbons off the produced water it handles and then sells or disposes of them, the Commission expects a monthly P-18 for it.
Facilities that typically file
- Commercial saltwater disposal (SWD) facilities that recover skim oil
- Water-gathering systems that separate and sell condensate
- Single and multiple operator produced water disposal systems that recover nonidentifiable hydrocarbons
Zero-skim months and returned volumes
A month with no recovered skim is still reported; repeated unexplained zero-skim months can read as unreported recovery. Identifiable volumes returned to the producing property in the same reporting period are not reported, but, per Statewide Rule 56, you must notify the Commission district office by telephone before returning them.
One report per facility, every month
Each qualifying facility files its own P-18, every month, due by the 15th of the month following the reporting period. The report is filed online through LoneSTAR; paper filings are only accepted through August 2026.
Frequently asked
Do I file a P-18 if I run a commercial SWD that skims oil?
Yes. If your saltwater disposal facility recovers skim oil or condensate and sells or disposes of it, you are expected to file a monthly P-18 for that facility.
Do water-gathering systems file a P-18?
Yes, when they recover and sell or dispose of skim liquid hydrocarbons. Both single and multiple operator produced water disposal systems report their nonidentifiable recovered hydrocarbons on the P-18.
Do I file if I had no skim oil this month?
Yes. Zero-skim months are still reported. A pattern of unexplained zero-skim months can read to a reviewer as unreported recovery, so report them honestly with documentation.
Who at my company can file the P-18?
Anyone your LoneSTAR Delegated Administrator grants filing rights to, or, on your sign-off, a compliance firm that prepares and submits it for you.
Official sources
Emergent Environmental is not affiliated with the Railroad Commission of Texas. This guide is informational; the official P-18 instructions are authoritative.
Let us file it for you
You send the data, we handle the rest, reconciled to the barrel and filed by the 15th. Start with a free review of your trailing P-18 filings.