Current CCS regulations contemplate conversion of EOR operation to CCS performance. Moderated by McAfee & Taft environmental attorney Mary Ellen Ternes, this session focuses on challenges in converting EOR carbon dioxide flood operations to fully performing carbon dioxide geologic sequestration. Discussion includes the EPA’s Clean Air Act mandatory greenhouse gas reporting rule Subpart RR and Safe Drinking Water Act underground injection control Class VI well requirements, including monitoring, reporting and verification plans, mass balance approaches and annual monitoring activities, as well as reporting rule Subparts UU and UIC Class II requirements for underground injection.