OFFICE OF INSPECTOR GENERAL 

Catalyst for Improving the Environment 

Evaluation Report 

Federal Facilities in Chesapeake Bay 

Watershed Generally Comply with 

Major Clean Water Act Permits 

 Report No. 2007-P-00032 

 September 5, 2007 
 

 

 

 

Report Contributors:	 Alicia Mariscal 

Jill Ferguson

 Ira Brass

 Dan Engelberg 

Abbreviations 

DoD Department of Defense 

EPA U.S. Environmental Protection Agency 

NOV Notice of Violation 

NPDES National Pollutant Discharge Elimination System 

OIG Office of Inspector General 

PCS Permit Compliance System 

SNC Significant Noncompliance 

Cover photo: The Naval Surface Warfare Center Indian Head is a Federal facility within the 

Chesapeake Bay watershed that operates under a major NPDES permit. The 

center is a tenant of the Naval Support Facility Indian Head. The Indian Head 

facility is on a peninsula surrounded by the Potomac River and the Mattawoman 

Creek in Charles County, Maryland, about 20 miles south of Washington, DC. 

(Photo from Naval Support Facility Indian Head Website). 
 

 

U.S. Environmental Protection Agency 2007-P-00032
 

Office of Inspector General September 5, 2007
 

At a Glance 

Catalyst for Improving the Environment 

Why We Did This Review 

Much effort is being expended to 

clean up impaired waters in the 

Chesapeake Bay watershed. We 

looked at whether Federal 

facilities in the watershed were 

in compliance with Clean Water 

Act permitted levels, what tools 

were available for the U.S. 

Environmental Protection 

Agency (EPA) to identify permit 

noncompliance and enforce 

compliance, and whether EPA’s 

actions were improving 

compliance at Federal facilities. 

Background 

One hundred Federal facilities 

discharge into the Chesapeake 

Bay or its tributaries. Nine of 

those facilities operate under 

major National Pollutant 

Discharge Elimination System 

(NPDES) permits. The Clean 

Water Act provides that any 

discharges into U.S. waters must 

be permitted by EPA or a State. 

The NPDES program assigns 

discharge amounts to all 

facilities, including Federal ones. 

EPA and States regulate 

compliance with permitted levels 

and take enforcement actions 

when necessary. 

For further information, 

contact our Office of 

Congressional and Public Liaison 

at (202) 566-2391. 

To view the full report, 

click on the following link: 

www.epa.gov/oig/reports/2007/ 

20070905-2007-P-00032.pdf 

Federal Facilities in Chesapeake Bay Watershed 

Generally Comply with Major Clean Water Act Permits

 What We Found 

Overall, EPA and the States are doing well managing how major Federal 

facilities comply with their NPDES permits. In EPA’s last reporting period 

(2004), major Federal facilities in the Chesapeake Bay watershed had a lower 

rate of Significant Noncompliance than other Federal and non-Federal majorpermit facilities nationwide. 

EPA and States have a variety of formal and informal tools available to enforce 

Federal facility compliance with NPDES permits. They employed several of 

these tools with major Federal facilities. These tools included: 

• Multimedia, voluntary agreement, and media press release approaches 

• Notices of Violation 

• An administrative order 

• A Federal Facility Compliance Agreement 

Also, EPA developed the Wastewater Integrated Strategy, which seeks to 

eliminate Federal facility Significant Noncompliance with NPDES permit limits. 

EPA also worked with the Department of Defense to make NPDES permit 

compliance a higher priority at military installations (eight of the nine Federal 

facilities with major NPDES permits are at military installations). Due to our 

small sample size, we did not determine the tools’ relative effectiveness in 

bringing about and maintaining compliance. 

We make no recommendations in this report. Both Region 3 and the Chesapeake 

Bay Program Office declined to provide formal responses to the draft report. 
 

 

 

 

Assistant Inspector General, Office of Program Evaluation 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF 

INSPECTOR GENERAL 

September 5, 2007 

MEMORANDUM 

SUBJECT: Federal Facilities in Chesapeake Bay Watershed 

Generally Comply with Major Clean Water Act Permits 

Report No. 2007-P-00032 

FROM: Wade T. Najjum 

TO: Donald S. Welsh 

 Regional Administrator, Region 3 

 Jeffrey L. Lape 

Director, Chesapeake Bay Program Office 

This is our report on Chesapeake Bay Federal facilities’ compliance with the Clean Water Act 

evaluation conducted by the Office of Inspector General (OIG) of the U.S. Environmental 

Protection Agency (EPA). This report describes our findings about how the Agency is managing 

Federal facility compliance with their National Pollutant Discharge Elimination System 

(NPDES) permits and the tools available to the EPA and States to enforce compliance. We make 

no recommendations in this report. This report represents the opinion of the OIG and does not 

necessarily represent the final EPA position. 

The estimated cost of this report – calculated by multiplying the project’s staff days by the 

applicable daily full cost billing rates in effect at the time – is $184,914. 

Action Required 

Because this report contains no recommendations, you are not required to respond to this report. 

We have no objections to the further release of this report to the public. This report will be 

available at http://www.epa.gov/oig. 

If you or your staff have any questions regarding this report, please contact me at 202-566-0827 

or Najjum.Wade@epa.gov; Dan Engelberg, Director of Program Evaluation, at 202-566-0830 or 

Engelberg.Dan@epa.gov; or Ira Brass, Project Manager, at 212-637-3057 or Brass.Ira@epa.gov. 
Federal Facilities in Chesapeake Bay Watershed 

Generally Comply with Major Clean Water Act Permits 

Table of Contents 

Purpose ................................................................................................................................... 1 

Background .......................................................................................................................... 1
 

 

Federal Facilities in Chesapeake Bay Watershed...................................................... 2 

EPA and State Roles and Responsibilities for Federal Facility Oversight.................. 2 

 

Noteworthy Achievements..................................................................................................... 3 

Scope and Methodology ........................................................................................................ 3 

 

Results of Evaluation ............................................................................................................. 4
 

EPA and States Address Major Federal Facility Noncompliance............................... 4 

EPA and States Use a Variety of Enforcement Tools to Address Noncompliance .... 5 

Agency Response................................................................................................................... 6 

Status of Recommendations and Potential Monetary Benefits.......................................... 7 

Appendices 

A Federal Facility Significant Noncompliance by Quarter.................................... 8 

B Pertinent Prior Reviews........................................................................................ 9 

C Distribution ............................................................................................................ 10 

 
 

Purpose 

Federal facilities have a responsibility to comply with Federal environmental laws such as the 

Clean Water Act. At the request of the Office of Management and Budget, we reviewed Federal 

facilities in the Chesapeake Bay watershed and their compliance with National Pollutant 

Discharge Elimination System (NPDES) permits under the Clean Water Act. We also reviewed 

corresponding U.S. Environmental Protection Agency (EPA) and State enforcement actions and 

their impact on the watershed. The following four questions guided our review: 

1.	 What is EPA’s role and responsibility for oversight of Federal facilities holding NPDES 

permits? 

2.	 To what extent are Federal facilities in the Chesapeake Bay watershed complying with 

NPDES permit levels? 

3.	 In the Chesapeake Bay watershed, what tools are available for EPA to identify NPDES 

permit noncompliance and enforce compliance at Federal facilities, and are they being 

utilized? 

4.	 Are EPA’s actions improving NPDES compliance at Federal facilities in the Chesapeake 

Bay? 

The first question is addressed in the Background section of this report; the remaining questions 

are addressed in the Results of Evaluation section. 

Background 

The Chesapeake Bay is North America’s largest and most biologically diverse estuary. It is 

home to more than 16 million people and 3,600 species of plants, fish, and animals. The Bay’s 

watershed, the geographic area that drains water to the Bay, covers 64,000 square miles. The 

watershed includes parts of six States – Delaware, Maryland, New York, Pennsylvania, Virginia, 

and West Virginia – as well as all of the District of Columbia. 

Over time, the Bay and its tributaries have suffered from excess nutrients and sediment, 

impairing water quality and affecting aquatic life. Formal efforts to restore the health of the Bay 

have been ongoing since 1983, when the Chesapeake Bay Program was formed to lead and direct 

restoration of the Bay. The program is a regional partnership of State and Federal agencies, 

academic institutions, and non-governmental organizations. Bay program partners include EPA, 

Maryland, Pennsylvania, Virginia, the District of Columbia, and the Chesapeake Bay 

Commission (a tri-State legislative advisory body). Delaware, New York, and West Virginia are 

also actively involved in the Bay program but are not signatories to the 2000 agreement for 

cleaning up the Bay.1

 EPA and its Chesapeake Bay Program Office, which is part of EPA’s 

Region 3, coordinate Bay restoration activities and implementation of strategies. 

1 Chesapeake 2000 is the latest agreement whereby the Chesapeake Bay Program partners recommitted to their 

overall mission of Bay restoration, and established the goal of improving water quality in the Bay and its tributaries 

so that these waters may be removed from EPA’s impaired waters list by 2010. 

1
 
 

 

 

Improving water quality in the Chesapeake Bay is dependent, in part, on reducing pollution from 

point sources. To decrease pollutants entering the waters of the Chesapeake Bay, EPA, under the 

Clean Water Act, requires all point source dischargers to abide by an NPDES permit. 

Federal Facilities in Chesapeake Bay Watershed 

According to EPA, 100 Federal facilities in the watershed discharge into the Chesapeake Bay or 

a tributary of the Bay. The EPA Permit Compliance System (PCS) database tracks EPA regional 

and State compliance and enforcement data for the NPDES program under the Clean Water Act. 

According to PCS, 11 major permits are issued to 9 Federal facilities in the Chesapeake Bay 

Watershed under the NPDES program.2

 Facilities with major permits are those that discharge 

more than 1 million gallons per day. These major facilities are located in Maryland, 

Pennsylvania, Virginia, and the District of Columbia (see Appendix A). 

Eight of the nine major-permit holders are Department of Defense (DoD) installations. The 

other major-permit facility, which supplies drinking water for the District of Columbia and 

northern Virginia, is operated by the U.S. Army Corps of Engineers. The 91 other Federal 

facilities are considered minor permit facilities under the NPDES permit classification system. 

EPA and State Roles and Responsibilities for Federal Facility Oversight 

For the most part, EPA and State roles and responsibilities for Federal facility oversight are the 

same as for non-Federal facilities. Agency and State staff may work with those from EPA 

Region 3’s Office of Enforcement, Compliance, and Environmental Justice during inspections. 

However, Agency staff members are located in separate offices and usually are not involved in 

Federal facility oversight or enforcement. Unlike some other statutes, the Clean Water Act does 

not grant EPA or States with authority to levy penalties against Federal facilities. 

NPDES permits require NPDES-permitted facilities to self-report the contents and volume of 

water discharged through discharge monitoring reports. These reports are sent to States, many in 

paper format, and then uploaded by the State to an EPA data system. The system tracks both 

major and minor permits. However, information on violations and enforcement are not required 

for minor permits. 

Title 40, Code of Federal Regulations, Section 123.45 requires EPA and States to report when 

NPDES major dischargers are in noncompliance with their permit conditions. Reportable 

Noncompliance can include a violation of effluent limits in NPDES permits, violations of 

enforcement orders or schedules for compliance with permit conditions, failure to provide 

compliance schedule reports, unauthorized bypasses or discharges, and failure to submit 

discharge monitoring reports on time. 

2

 PCS lists the City of Aberdeen facility as a Federal facility, and we originally included it in this list of major 

facilities. We learned that the City of Aberdeen has operated this facility during the time period reviewed under this 

evaluation. We verified that this facility is not a Federal facility by reviewing the facility’s last two active permit 

documents. EPA staff indicated they will remove the incorrect designation. 

2
 
 

 

Significant Noncompliance (SNC) is a subset of Reportable Noncompliance. SNC involves 

priority violations of NPDES permits that EPA believes merit special attention, including: 

•	 Violations of monthly and non-monthly effluent limits for two or more months during 

two consecutive quarterly review periods by (a) 20 percent for toxic pollutants, such as 

metals; and (b) 40 percent for conventional pollutants, such as total suspended solids. 

•	 Non-effluent violations, such as bypasses or unpermitted discharges, which cause or have 

the potential to cause a water quality problem, such as beach closings. 

•	 Permit compliance schedule violations. 

•	 Reporting violations, including failure to submit timely discharge monitoring reports 

(filing the report more than 30 days late or not at all). 

•	 Violations of existing enforcement orders, including judicial or administrative orders. 

Federal facilities, like other NPDES permitted facilities, are subject to periodic inspections, 

compliance reviews, and enforcement actions where applicable.3 According to EPA Region 3 

staff, States conduct 90 percent of monitoring and compliance assurance at Federal facilities. 

EPA performs civil enforcement when necessary, mainly when a State requests assistance. 

Noteworthy Achievements 

Chesapeake Bay Federal facilities had lower SNC rates in the 2004 reporting period than other 

facilities nationwide. EPA works with Federal agencies to involve facilities in efforts to 

improve, enhance, and recognize success in pollution reduction. These efforts include activities 

such as: wetland restoration, forest stewardship, and leadership in storm water management. The 

Businesses for the Bay Program is one example of how the EPA recognizes Federal partner 

efforts. This program is comprised of a voluntary team of forward-looking businesses, 

industries, government facilities, and other organizations within the watershed that strives for 

voluntary implementation of pollution prevention practices. In addition, over the past 2 years, 

EPA worked with DoD to make NPDES permit compliance a higher priority at military 

installations. As a result, in January 2007, the DoD Office of the Under Secretary of Defense 

issued a directive with a goal of zero SNCs at installations to encourage compliance with 

permitted levels of discharge. DoD facilities must prepare and present a corrective action plan 

when in SNC. DoD expects to meet or closely approach the zero SNC goal in the near future. 

Scope and Methodology 

We conducted our review from December 2006 to April 2007 in accordance with Government 

Auditing Standards, issued by the Comptroller General of the United States. We focused on 

compliance rates of the nine Federal facilities in the watershed with major NPDES permits (see 

Appendix A). Major facilities account for a large share of the pollutants discharged. To evaluate 

compliance, we used PCS data to look at quarterly rates of SNC during Fiscal Years 2000 to 

2006 (October 1999 to September 2006). The EPA Office of the Inspector General (OIG) data 

3

 According to EPA guidance, major-permit holders should be inspected annually; no recommended frequency 

exists for minor permit holders. 

3
 
mining staff pulled data directly from PCS. Where possible, we verified PCS facility data with 

EPA Region 3, DoD management, and State and facility staff, as well as through applicable files. 

To obtain an understanding of the Federal facility oversight process, we interviewed EPA staff 

and managers from EPA Region 3’s Office of Enforcement, Compliance, and Environmental 

Justice; Water Protection Division; and Chesapeake Bay Program Office. We also interviewed 

Office of Enforcement and Compliance Assurance staff at EPA Headquarters. We identified 

Federal facilities in the watershed through the use of designated Chesapeake Bay watershed 

codes. To obtain information on the State roles and perspectives, we interviewed NPDES permit 

enforcement staff from Maryland, Virginia, and Pennsylvania. 

Working through DoD, we arranged site visits at two major facilities and spoke by phone with 

personnel at a third. Each of the three facilities was located in a different Chesapeake Bay 

signatory State. We also met with an EPA attorney regarding the U.S. Army Corps of 

Engineers’ Washington Aqueduct facility. We contacted representatives from the National 

Oceanic and Atmospheric Administration and non-governmental organizations to obtain 

information and input. 

We reviewed those internal controls relevant to our objectives. Our study was limited to the 

small number of major-permit Federal facilities located in the Chesapeake Bay watershed. 

We reviewed relevant prior reports issued by the EPA OIG and the U.S. Government 

Accountability Office; they are listed in Appendix B. 

Results of Evaluation 

EPA and States Address Major Federal Facility Noncompliance 

Based on our review of PCS data, EPA and States appear to be doing well in managing majorpermit Federal facility compliance with the Clean Water Act. In its last national report on 

Federal facility compliance, covering Fiscal Years 2003-2004, EPA reported that NPDES 

permitted Federal facilities, including the Chesapeake Bay facilities, had lower rates of SNC than 

non-Federal facilities nationwide. In 2004, only one of the nine Chesapeake Bay Federal 

facilities, or 11 percent, was in SNC. This compares to a national 2004 SNC rate (increasing 

since 2001) of 22 percent for all NPDES-permitted Federal Government facilities and 20 percent 

for non-Federal facilities. EPA and State enforcement representatives said there were no 

significant compliance concerns at major Federal facilities in the Chesapeake Bay watershed. 

Over our 7-year review period (Fiscal Years 2000-2006), four of the nine major Chesapeake Bay 

NPDES permitted Federal facilities were in SNC at least once (see Appendix A). The 

Washington Aqueduct was in SNC for 11 of the 28 quarters, while Naval Surface Warfare 

Center Indian Head was in SNC for 5 quarters. The U.S. Marine Corps Base Quantico (which 

had two permits) and Fort Indiantown Gap were each in SNC for 3 quarters. The reasons for 

SNC at the four major facilities varied, as follows. 

•	 The Fort Indiantown Gap facility had upgraded water treatment processes to a level that 

would enable it to achieve permit limits for sediments, while the Washington Aqueduct 

4
 
 

 

had not. The need to upgrade had been identified as new permit limits were issued for 

both facilities. However, neither facility had completed renovations before the new 

permit limits went into effect, resulting in SNC designations. Upgrades at the Fort 

Indiantown Gap facility are complete and the facility is meeting its permit conditions. 

SNC issues at the Washington Aqueduct facility will remain unresolved until the facility 

upgrades are complete (expected by December 2009). 

•	 U.S. Marine Corps Base Quantico was in SNC for effluent violations under permit 

VA0028363 for the quarters ending June and September 2002, and resolved both 

violations in December 2002. Under permit VA0002151, the facility was also in SNC for 

a chlorine maximum violation due to a potable waterline break for the quarter ending 

September 2006. Virginia considered the break to be an accident. In March 2007, after 

the facility had repaired the broken line, Virginia listed the SNC as resolved. 

•	 The Naval Surface Warfare Center Indian Head facility reported high levels of total 

suspended solids at one monitoring point from May 2005 to January 2006. Facility staff 

disagreed with the SNC designation, contending that a laboratory analyst failed to follow 

Standard Operating Procedures during testing. Though the SNC designation may be at 

issue, all open items have been concluded on this case except for a storm water pollution 

prevention plan, which EPA is awaiting. 

EPA and State staff agreed that major-permitted Federal facilities are not large contributors to 

the water quality impairments for the Chesapeake Bay; there are few of them and they generally 

meet their permit limits. Data from EPA and States, as well as interviews with representatives 

from other Federal agencies and environmental organizations, supported this assertion. Further, 

NPDES permits for major-permit Chesapeake Bay Federal facilities are not for nutrients, which 

are a primary cause of the water quality degradation and loss of aquatic life in the Bay. 

EPA and States Use a Variety of Enforcement Tools to Address Noncompliance 

EPA and States used a variety of formal and informal enforcement tools to bring Federal 

facilities in SNC back into compliance. According to Region 3 and Chesapeake Bay Program 

Office staff, the most effective tools have been the multimedia, voluntary agreement, and media 

press release approaches. Another available tool for encouraging compliance is the EPA Federal 

Facility Enforcement Office’s Wastewater Integrated Strategy. The strategy seeks to eliminate 

Federal facility SNC with NPDES permit limits. This initiative included extensive outreach, 

information gathering, and a compliance workshop attended by environmental managers from 

DoD and Federal civilian facilities. This effort impressed upon the Federal facility community 

the need to bolster its compliance with NPDES requirements. 

For Federal facilities in SNC reviewed, reported formal actions included an administrative order 

and a Federal Facility Compliance Agreement. Official informal enforcement actions included 

15 Notices of Violation (NOVs). Given the small sample, we were not able to determine which 

tools were most/least effective in maintaining compliance and bringing noncompliant facilities 

into compliance. Examples of enforcement actions taken follow. 

5
 
 

•	 The Naval Surface Warfare Center Indian Head facility was in SNC five times during 

the analysis timeframe. On February 28, 2003, EPA issued an NOV to the facility, and 

the facility responded on March 13, 2003. On October 24, 2005, EPA issued two NOVs 

resulting from a May 2004 EPA multimedia inspection. As outlined in an October 18, 

2006, EPA letter, citations from the 2004 multimedia inspection have been resolved. 

EPA is awaiting the new storm water pollution prevention plan. 

•	 The U.S. Marine Corps Base Quantico facility was in SNC three times during the 

analysis timeframe. Virginia issued 11 NOVs to the facility between 2002 and 2004 and 

an administrative consent order on July 10, 2003. Virginia believed the facility should 

not have been listed as being in SNC for the quarter ending September 2006. On 

October 6, 2006, Virginia issued an NOV to the facility. Virginia considered the 

violation to be resolved in March 2007. 

•	 The Washington Aqueduct facility was in SNC for 11 quarters during the analysis 

timeframe. EPA issued an NOV to the facility on October 9, 2002. EPA issued an 

administrative order the U.S. Army Corps of Engineers on June 12, 2003, for $70 million 

(the cost of the upgrades). EPA also entered into a Federal Facility Compliance 

Agreement with the Army Corps on June 12, 2003, to enable the development of a 

lengthy compliance schedule. The facility had a compliance schedule violation on 

June 3, 2005. 

•	 The Fort Indiantown Gap facility has been in SNC for the three quarters stretching from 

July 2005 to March 2006. The State did not issue a formal enforcement action to the 

facility because the facility was working to complete facility upgrades suggested by the 

State in 1997. The facility completed the upgrades in 2006 and current discharges 

comply with permit requirements. 

Agency Response 

We are not making any recommendations in this report, and both Region 3 and the Chesapeake 

Bay Program Office declined to provide formal responses to the draft report. 

6
 
 

 

 

 

 

 

 

 

 

Status of Recommendations and 

Potential Monetary Benefits 

POTENTIAL MONETARY 

RECOMMENDATIONS BENEFITS (in $000s) 

Planned 

Rec. Page Completion Claimed Agreed To 

No. No. Subject Status1 Action Official Date Amount Amount 

No recommendations 

1 O = recommendation is open with agreed-to corrective actions pending; 

C = recommendation is closed with all agreed-to actions completed; 

U = recommendation is undecided with resolution efforts in progress 

7
 
Federal Facility Significant Noncompliance by Quarte

(Fiscal Years 2000-2006) 

2000 2001 2002 2003 2004 

Facility Name State Permit # 1 2

3

4 1 2

3

4 1 2

3

4 1 2

3

4 1 2

3

4 

Fort Detrick WWTPArea C MD MD0020877 Fort Indiantown Gap STP PA PA0028142 Fort Meade WWTP MD MD0021717 Naval Surface Warfare Center - Indian Head MD MD0003158 Naval Surface Warfare Center - Indian Head MD MD0020885 U.S. Army Garrison – APG MD MD0021229 US Marine Corps - MCB Quantico VA VA0002151 US Marine Corps -MCB Quantico VA VA0028363 US Navy - Naval Station Norfolk VA VA0004421 Washington Aqueduct DC DC0000019 

Source: OIG analysis of EPA data 

Quarters – by Fiscal Year: 1: October – December 2: January – March 3: April – June 4: July – September 

Abbreviations: APG: Aberdeen Proving Ground MCB: Marine Corps Base STP: Sewage Treatment Plant WWTP: Waste Water Treatment Plant 

Legend SNC 

No SNC 

8
 
Appendix B 

Pertinent Prior Reviews 

EPA OIG 

•	 Saving the Chesapeake Bay Watershed Requires Better Coordination of Environmental and 

Agricultural Resources (2007-P-00004), November 20, 2006 

•	 EPA Grants Supported Restoring the Chesapeake Bay (2006-P-00032), September 6, 2006 

•	 Congressionally Requested Review of EPA Region 3’s Oversight of State National Pollutant 

Discharge Elimination System Permit Programs (2005-S-00002), October 29, 2004 

U.S. Government Accountability Office 

•	 Chesapeake Bay Program: Improved Strategies Are Needed to Better Assess, Report, and 

Manage Restoration Progress (GAO-06-96), October 2005 

•	 Water Pollution: Stronger Enforcement Needed to Improve Compliance at Federal 

Facilities (GAO-RCED89-13), December 1988 

9
 
Appendix C 

Distribution 

Office of the Administrator 

Regional Administrator, Region 3 

Director, Chesapeake Bay Program Office 

Assistant Administrator, Office of Water 

Assistant Administrator, Office of Enforcement and Compliance Assurance 

Agency Followup Official (the CFO) 

Agency Followup Coordinator 

General Counsel 

Associate Administrator for Congressional and Intergovernmental Relations 

Associate Administrator for Public Affairs 

Director, Office of Regional Operations 

Audit Followup Coordinator, Region 3 

Acting Inspector General 

10