Respondent failed to have NPDES permit coverage as required under the Clean Water Act for discharges of pollutants to waters of the U.S. from November 2, 1998 until January 2001. Respondent discharged without a permit from the following offshore oil and gas platforms in federal waters in the Outer Continental Shelf of the Gulf of Mexico: MAIN PASS 111, MAIN PASS 112, MAIN PASS 116, MAIN PASS 125, and MAIN PASS 181.