Respondent made a Self Disclosure under EPA's Self Disclosure Audit Policy about the failure to have an NPDES permit for oil and gas activities in East Cameron 245 of the Gulf of Mexico from Oct 1998 until Dec 2002. Respondent stated that they behaved and monitoried as if they were covered by the OCS general permit, but just failed to submit the Notice of Intent application. Respondent asserted to EPA that there was no economic benefit. Under the Self Disclosure audit policy, EPA only has to collect economic benefit and can waive the gravity portio of the penalty and in the case, EPA is settling for $0.